Dependent Personnel Services
(1) Reserving Articles 15, 17, 18, 19 and 20, salaries, wages and similar fees that a person resident in a Contracting State draws from regular employment can only be taxed in this State unless the work is performed in the other Contracting State. If the work is performed there, the fees earned for it can be taxed in the other State.
(2) Regardless of the Paragraph above, fees that a person resident in one Contracting State earns for regular employment performed in the other Contracting State can only be taxed in the former State if:
- (a) the recipient does not reside in the other State for a total of more than 183 days within a 12 months period that begins or ends during the affected fiscal year; and
- (b) the fees is paid by or for an employer who is not resident in the other State; and
- (c) the fees is not born by a permanent establishment that the employer owns in the other State.
(3) Regardless of the above provisions of this Article, fees for regular employment that is performed on board a sea vessel or aircraft that is operated in international traffic or on board a vessel of inland navigation will be taxed in the Contracting State in which the enterprise's place of effective management is located.