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CHAPTER 1 - General Provisions
CHAPTER 2 - Taxation of Income
CHAPTER 3 - Inheritance Tax
CHAPTER 4 - Registration Fees Other than Inheritance Tax-Stamp Duty
CHAPTER 5 - Administrative Assistance
CHAPTER 6 - Special Provisions
CHAPTER 7 - Transitional Provisions
CHAPTER 8 - Final Provisions
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 16

Dependent Personal Services

(1) Subject to the provisions of Articles 17, 19, and 20 of this Regulation, salaries, wages and other similar remuneration received by a resident of a Member State in respect of paid employment shall be taxable only in that State unless the employment is exercised in another Member State or several Member States. If the employment is so exercised, such remuneration as is received thereof, may be taxed in that other State or in the other States.

(2) Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Member State in respect of paid employment exercised in one of the other Member States shall be taxable only in the first-mentioned State if:

  • (a) the recipient is present in one or several other States for a period or periods not exceeding in the aggregate 183 days during the fiscal year in question, and
  • (b)  the remuneration is paid by, or on behalf of, an employer who is not a resident of one of the other States, and
  • (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in one of the other States.

(3) Notwithstanding the preceding provisions of this Article, any remuneration derived in respect of paid employment exercised aboard a ship or aircraft operated in international traffic may be taxed only in the Member State in which the place of effective management of the enterprise is situated.