ARTICLE 15
Dependent Personal Services
(1) Subject to the provisions of Articles 16 to 19, salaries, wages and other similar remuneration derived by a resident of the sovereign territory of a Contracting Party in respect of an employment shall be taxable only in the sovereign territory of that Contracting Party unless the employment is exercised in the sovereign territory of the other Contracting Party. If the employment is so exercised, such remuneration as is derived thereby may be taxed in the sovereign territory of that other Contracting Party.
(2) Notwithstanding the provisions of paragraph (1), remuneration derived by a resident of the sovereign territory of a Contracting Party in respect of an employment exercised in the sovereign territory of the other Contracting Party shall be taxable only in the sovereign territory of the first-mentioned Contracting Party if:
- (a) the recipient is present in the sovereign territory of the other Contracting Party for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned, and
- (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the sovereign territory of the other Contracting Party, and
- (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the sovereign territory of the other Contracting Party.
(3) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, may be taxed in the sovereign territory of the Contracting Party in which the place of effective management of the enterprise which operates the ship or aircraft is situated.