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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Dependent Personal Services

(1) Subject to the provisions of Articles 16, 18 and 19, wages, salaries 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 State.

(2) Notwithstanding the provisions of paragraph (1), 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 twelve-month period beginning or ending during the relevant fiscal year in question; and
  • (b) the remunerations is paid by an employer or on behalf of an employer who is not a resident of the other State; and
  • (c) the remunerations is not borne by a permanent establishment or a fixed base which 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 by an enterprise of a Contracting State, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.