background image
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.


Dependent Personal Services

(1) Subject to the provisions of Article 16 to Article 19 of this Convention, salaries, wages and other similar remuneration derived from employment by a resident of a Contracting State 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 Contracting State.

(2) Notwithstanding the provisions of paragraph (1), 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 recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days during any twelve-month period, beginning or ending during the relevant fiscal year;
  • (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State, and
  • (c) the expenses for the remuneration are not borne by a permanent establishment or a fixed base that the employer has in the other State.

(3) Notwithstanding the preceding provisions of this Article, remuneration derived from employment exercised aboard a ship or aircraft in international traffic or aboard inland water transportation shall be taxable only in the Contracting State in which the place of effective management of the enterprise that operates the ship or the aircraft is situated.

(4) The provisions of paragraph (2) above, shall not apply to remuneration for work carried out within the framework of a temporary employment agency.