Article 15 DEPENDENT PERSONAL SERVICES
Article 15
DEPENDENT PERSONAL SERVICES
1. Subject to the provisions of Articles 16, 18, 19 and 20 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of 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, such remuneration as is derived therefrom 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 an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
1) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and
2) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and
3) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State.
3. Notwithstanding the provisions of paragraphs 1 and 2 of this Article, salaries and other remuneration derived by a resident of a Contracting State for work carried out in the other Contracting State are not taxed in that other Contracting State if:
1) employment is exercised in connection with a building site, a construction, assembly or installation project during a period not exceeding 12 months in accordance with subparagraph 7 of paragraph 2 of Article 5 of this Agreement;
2) employment is exercised aboard of a ship, aircraft or road vehicle operated in international traffic by an enterprise of the first-mentioned Contracting State of which the enterprise is a resident.