Dependent Personal Services
(1) Subject to the provisions of Articles 16, 18 and 19 of this Convention, wages, salaries and other similar 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 this Article, 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 of 183 days during any twelve-month period commencing or ending in 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 which the employer has in the other State.
(3) Notwithstanding the preceding provisions of this Article, remuneration derived from an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State, may be taxed in that Contracting State.