ARTICLE 15
Personal Services
(1) Subject to the provisions of Articles 16, 19, 20 and 21, remuneration derived by an individual who is a resident of a Contracting State in respect of an employment or a profession shall be taxable only in that State unless the employment or profession is exercised in the other Contracting State. If the employment or profession is so exercised, such income as is derived therefrom may be taxed in the other Contracting 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 employment or profession exercised in the other Contracting State be taxable only in the first-mentioned State if:
- (a) the individual is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar 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 operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.