(1) Subject to the provisions of Articles 15, 17, 18 and 19, 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:

• (a) the recipient is present in the other State 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 other State, and
• (c) the remuneration is not borne by a permanent establishment which the employer has in the other State.

(3) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment which an individual who is a resident of one of the Contracting States which is borne by a fixed place of business, situated in a cross-border economic area and through which the common border between the Contracting State runs, shall be taxable only in the State of which the individual is a resident, unless under Council Regulation (EEC) No 1408/71 of 14 June 1971, Council Regulation (EC) No 883/2004 of 29 April 2004, or under a regulation of the European Union which substitutes them following the signature of this Convention, this individual is subject to the legal provisions of the other State. If under Council Regulation (EEC) No 1408/71 of 14 June 1971, under Council Regulation (EC) No 883/2004 of 29 April 2004, or under a regulation of the European Union which substitutes them following the signature of this Convention, the individual is subject to the legal provisions of the other State, this remuneration may be taxed in that other State.

(4) Notwithstanding the preceding provisions of this Article, 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, may be taxed in the Contracting State in which the place of effective management of the enterprise operating such ship, aircraft or boat is situated.