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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) Without prejudice to the provisions of Articles 16, 18, 19, 20 and 21 hereof, salaries, wages and other similar remuneration taken by a resident of a Contracting State – for an employment – shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration shall be taxed in that other Contracting State.

(2) Notwithstanding the provisions of above-mentioned paragraph (1), remunerations gained by a resident in a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:

  • (a) The beneficiary is resident in other Contracting State for a period or periods not exceeding (183) days in aggregate period of twelve-months that starts or ends within the fiscal year concerned.
  • (b) The remuneration is paid by, or on behalf of, an employer which is not a resident in the other Contracting State.
  • (c) The remuneration is not incurred by a permanent establishment or a fixed base the employer owns in other Contracting State.

(3) Notwithstanding the previous provisions of the Article hereof, remuneration of:

  • (a) an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State; or
  • (b) an employment exercised by citizens of any of the two Contracting States to provide handling services for an international transport enterprise of a Contracting State;

may be taxed only in the Contracting State where the actual management headquarters of the enterprise is situated.