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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 18, 19, 20, 21, and 22 of this Convention, salaries, wages and other similar remuneration derived from employment by a resident of a Contracting State in shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived thereof may be taxed in that other State.

(2) Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Contracting State in respect of employment exercised in the other Contracting State may be taxed in the first-mentioned State if the three conditions below are simultaneously met:

  • (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;
  • (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 or a fixed base which the employer has in the other State.

(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 in the Contracting State in which the place of effective management of the enterprise is situated.