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- Agreement between the Government of the Islamic Republic of Iran and the Government of the Russian Federation for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with Respect to Taxes on Income and on Capital (Tehran, March 5, 1998)
- Article 15 INCOME FROM DEPENDENT PERSONAL SERVICES
Article 15 INCOME FROM DEPENDENT PERSONAL SERVICES
Article 15
INCOME FROM DEPENDENT PERSONAL SERVICES
1. Subject to the provisions of Article 16, 18, 19 and 20 of this Agreement 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 Contracting 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 Contracting State.
2. Notwithstanding the provisions of paragraph 1, 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 Contracting State if:
a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelvemonths period commencing or ending in the fiscal year concerned; and
b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and
c) the remuneration is not borne by a permanent establishment or fixed base which the employer has in the other Contracting State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship, boat, aircraft, road or railway vehicle operated in international traffic by an enterprise of a Contracting State ,may be taxed in that Contracting State.