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Article 15 Employment

Article 15
Employment

1) Salaries, wages and other similar remuneration, a resident of a Contracting State in respect of an employment Subject to the provisions of Articles 16, 18, 19 and 20 be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration may be received for them taxed in that other State.

2) Remuneration which a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall, notwithstanding the provisions of paragraph 1 be taxable only in the first-mentioned State if all the following conditions are met:

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, and

b) the remuneration is paid by the employer or the employer who is not resident in the other State, and

c) the remuneration is not borne by a permanent establishment or fixed base which the employer has in the other State.

3) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship, boat or aircraft operated in international traffic operated by a resident of a Contracting State taxed in that State.

4) The term "employer" mentioned in paragraph 2, letter b) indicates the person has the right of the work and bearing the responsibility and risk associated with the performance of work.