ARTICLE 15
Dependant Personal Services
(1) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and remuneration of a similar nature that a person resident in one Contracting State earns from the exercise of dependant personal service may be taxed in the other Contracting State only if the employment is exercised in that other State.
(2) Notwithstanding the provisions of paragraph (1), remuneration received by a person resident in one Contracting State for dependant personal service exercised in the other Contracting State may be taxed in the first-mentioned State, provided all the following conditions have been fulfilled:
- (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days during any 12-month period beginning or ending in the fiscal year concerned; and
- (b) the remuneration is paid by an employer 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 or a fixed that the employer has in the other State.
(3) Notwithstanding the preceding provisions of this Article, remuneration received in respect of an employment for dependant personal service exercised aboard a ship or an aircraft in international traffic or for dependant personal service on board a ship for internal transport may be taxed in that Contracting State in which the place of effective management of the enterprise operating such ship, boat, or aircraft is situated.