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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, 18, 19 and 20 of this Convention, salaries, wages and other similar remuneration derived from employment by a resident of a Contracting State shall be taxable in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration shall be taxable in that other Contracting State.

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

  • (a) the beneficiary is a resident in the other Contracting State for a period or periods not exceeding in the aggregate 183 days within the relevant fiscal year;
  • (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 borne by a permanent establishment or a fixed base that the employer owns in other Contracting State.

(3) Notwithstanding the preceding provisions of this Article, remuneration from employment exercised on board a ship or aircraft operated in international traffic shall be taxable in the Contracting State in which the place of effective management of the enterprise is situated.

(4) The remuneration of on land employees in a Contracting State who were appointed by the national airtime authority of the other Contacting State shall exempted.