(1) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State, unless the employment is exercised in the other Contracting State. If the employment is exercised there, such remuneration as derived therefrom shall be taxable only in that other State.
(2) Notwithstanding the provisions of paragraph (1), remuneration derived by a resident of 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 recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned,
- (b) The remuneration is paid by, 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 fixed base which the employer has in the other State.
(3) Notwithstanding the provisions of paragraphs (1) and (2), remuneration in respect of an employment exercised on board a ship or aircraft in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.