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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 15

Dependent Personal Services

(1) Subject to the provisions of Articles 16, 17 18, 19, 20 and 21 of this Convention salaries, wages and other similar remuneration derived from employment by a resident of a Contracting State, from an employment exercised in the other Contracting State from exercising a dependent profession, shall be taxable only in that State, unless the employment is exercised in the other Contracting State. If the employment is so exercised, the remuneration so derived may be taxed in that other State.

(2) Notwithstanding the provision of paragraph (1) of this Article, remuneration derived by a resident of a Contracting State from employment carried on in the other Contracting State, shall be taxable only in the first-mentioned State if:

  • (a) the recipient is present in the other Contracting State for a period or periods not exceeding, in the aggregate one hundred eighty three (183) days;
  • (b) the remuneration is paid by an employer or, on behalf of an employer who is not a resident of the other State; and
  • (c) the remuneration is not borne by a permanent establishment or by a fixed base that the employer has in the other State.

(3) Notwithstanding the preceding provisions of this Article, remuneration and salaries derived from employment exercised aboard an aircraft, from an employment exercised in an airport (ground staff) including the income of the regional manager who is not a national of the Contracting State, shall be taxable only in the other Contracting State (the State of residence ).