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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.

ARTICLE 15

Dependent Personal Services

(1) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other types of similar remuneration derived by a resident of a Contracting State in respect of salaried employment 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), any remuneration derived by a resident of a Contracting State from a salaried employment exercised in the other Contracting State shall be taxable only in the first-mentioned State:

  • (a) if the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days during the relevant fiscal year, and
  • (b) if the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
  • (c) if the remuneration is not borne by a permanent establishment or a fixed place of business which the employer has in the other State.

(3) Notwithstanding the preceding provisions of this Article, any 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 located.