ARTICLE 15
Dependent Personal Services
(1) Salaries, wages and other 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 so exercised, such remuneration as is derived therefrom may be taxed 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:
- (1) It is paid in respect of an activity exercised in the other State for a period or periods not exceeding in the aggregate 183 days-including normal interruptions of work-in the calendar year, and
- (2) The remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and
- (3) The remuneration is not borne as such by a permanent establishment or a fixed base which the employer has in the other State.
(3) Notwithstanding paragraphs (1) and (2), remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, or aboard a boat engaged in inland waterways transport, shall be considered as an activity carried out in the Contracting State in which the place of effective management of the enterprise is situated and is taxable in that State.
(4) The provisions of this Article shall not apply to income to which Articles 16, 18, 19 and 20 apply.