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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, 19, 20 and 21 of this Convention, wages, salaries and other 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) of Article 11 of this Convention, 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; and
  • (b) the remuneration is paid by, or on behalf of an employer who is not a resident of the other State; and
  • (c) the remuneration is not borne by a permanent establishment 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, by an enterprise of a Contracting State may be taxed in that State in which the place of effective management of the enterprise is situated.