ARTICLE 14
Independent Personal Services
(1) Subject to the provisions of Article 15, 16 and 17 remuneration derived by an individual who is a resident of a Contracting State in respect of personal service (including the practice of a liberal profession) shall be taxable only in that State unless the service are rendered in the other Contracting State. If the services are so rendered, such remuneration as is derived there from may be taxed in that other State.
(2) Notwithstanding the provisions of paragraph 1, remuneration derived by an individual who is a resident of a Contracting State in respect of such service rendered 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 the fiscal year concerned, and
- (b) the remuneration is paid by, or on behalf of, a person who is not a resident of the other State, and
- (c) the remuneration is not borne by a permanent establishment which the person paying the remuneration has in the other State.
(3) Notwithstanding the provisions of paragraphs 1 and 2, remuneration in respect of an employment exercised aboard a ship or aircraft in international traffic, operated by an enterprise of a Contracting State, may be taxed in that State.