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ARTICLE 14

Income from Employment

(1) Subject to the dispositions in Articles 15, 17 and 18, the salaries, wages and other similar remuneration derived from employment by a resident of a Contracting State, shall be taxable only in that State, unless the employment is exercised in the other Contracting State. If the employment is so exercised, the remuneration so derived may be taxed in that other Contracting State.

(2) Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Contracting State from 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 during any relevant twelve-month period; and
  • (b) the remuneration is paid by an employer or on behalf of an employer who is not a resident of the other Contracting State; and
  • (c) the expense for the remuneration is not borne by a permanent establishment or fixed base that the employer has in the other State.

(3) Notwithstanding the preceding provisions of this Article, remuneration derived from employment exercised aboard a ship or aircraft operated in international traffic, may be taxed only in the Contracting State in which the place of effective management of the enterprise operating the ships, aircraft, trains or road vehicle is situated.