[Income from Employment]
(1) Failing specific agreements providing for special treatment in the matter, wages, salaries and other similar remuneration received by a person domiciled in one of the two Contracting States in respect of gainful employment shall be taxable only in that State, unless the employment occurs in the other Contracting State. If the employment occurs in the other Contracting State, the remuneration derived from it shall be taxable in the latter State.
(2) Notwithstanding the provisions of paragraph (1), remuneration received by a person domiciled in a Contracting State in respect of gainful employment in the other Contracting State shall be taxable only in the former State if:
- (a) the recipient resides in the other State for a period or periods not exceeding in the aggregate 183 days in the fiscal year concerned;
- (b) the remuneration is paid by or on behalf of an employer, who is not domiciled in the other State; and
- (c) The remuneration is not deducted from the profits of a permanent establishment or fixed base maintained by the employer in the other State.
(3) Notwithstanding the foregoing provisions of this Article, remuneration for work done on board a ship or aircraft in international traffic shall be taxable only in the Contracting State in which the enterprise is domiciled.