Dependent Personal Services
(1) Subject to the provisions of Article 16, 18, 19 and 20 of this Agreement, 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 done in the other Contracting State. If the employment is so done, such remuneration as is derived therefrom may be taxed in that other Contracting 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 that other Contracting State for a period or periods not exceeding in the aggregate 183 days, in any 12 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 that other Contracting State; and
- (c) the remuneration is not borne by a permanent establishment or a fixed base, which the employer has in the other Contracting State.
(3) Notwithstanding the preceding provisions of this Article, remuneration paid by an enterprise of a Contracting State in respect of an employment exercised aboard a ship, aircraft or road vehicle and railway operated in international traffic, may be taxed only in that Contracting State.