Dependent Personal Services
(1) Subject to the provisions of Articles 16 to 19 of this Convention, salaries, wages and other similar remuneration received by a resident of one of the Contracting States in respect of salaried 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 received thereof may be taxed in that other State.
(2) Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of one of the Contracting States in respect of salaried 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 during any period of 12 months beginning or ending during the fiscal year in question, and
- (b) The remunerations are paid by, or on behalf of, an employer who is not a resident of the other State, and
- (c) The charge of the remunerations is not borne by a permanent establishment or a fixed base which the employer has in the other State.
(3) The provisions of paragraph (2) of this Article shall not apply to remuneration in respect of an employment exercised in the context of hiring labour.
(4) Notwithstanding the preceding provisions of this Article, the remunerations derived in respect of salaried employment exercised aboard a ship or an aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is situated.