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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.

ARTICLE 15

Dependent Personal Services

(1) Subject to the provisions of Articles 16, 18 and 19 salaries, wages and other similar remuneration derived by a resident of a Contracting State from an employment 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 as is derived therefrom may be taxed in that other State.

(2) Notwithstanding the provisions of paragraph (1), 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 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 or a fixed base, which the employer has in the other State.

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