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ARTICLE 15

Dependent Personal Services

(1) Subject to the provisions of Articles 16, 17 and 18, salaries, wages 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 Contracting State.

(2) Notwithstanding the provisions of paragraph (1), salaries, wages and other 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 in 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 salaries, wages and remuneration are not borne by a permanent establishment or fixed base that the employer has in the other State.

(3) Notwithstanding the preceding provisions of this Article, salaries, wages and other remuneration derived by a resident of a State from employment exercised aboard a ship or aircraft operated in international traffic shall be taxable only in the State in which the place of effective management is situated.

(4) If a person is a citizen of a Contracting State and an employee of an enterprise situated in that State, carrying on activities pertaining to the operation of aircraft in international traffic, then any remuneration derived from such activity performed in the other Contracting State shall be taxable only in the first-mentioned Contracting State.