Common use of DEPENDENT PERSONAL SERVICES Clause in Contracts

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 and 21 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 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 Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 days in any 12-month 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 a 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 or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21 of this AgreementConvention, 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 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 Contracting State if: (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-twelve month period commencing or ending in the fiscal taxable year concerned; and; (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the that Contracting State in which the place of effective management of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles Article 16, 18, 19 and 21 of this Agreement20, salaries, wages and other similar remuneration derived by an individual who is a resident of a one of the 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 from that exercise may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived derives by an individual who is a resident of a the Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State ifif : (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-month period commencing the tax year or ending in year of income, as the fiscal year concerned; andcase may be, of that other State; (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) the remuneration is not borne by deductible in determining taxable profits of a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by a resident of one of the Contracting States may be taxed in the that Contracting State in which the place of effective management of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 and 21 of this Agreement20, salaries, wages and other similar remuneration derived by an individual who is a resident of a one of the Contracting State States 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 of this Article1, remuneration derived by an individual who is a resident of a one of the Contracting State States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if:if — (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-month period commencing the year of income or ending in fiscal year, as the fiscal year concernedcase may be, of that other State; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) the remuneration is not borne by deductible in determining the taxable profits of a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by a resident of one of the Contracting States may be taxed in the that Contracting State in which the place of effective management of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19,20 and 21 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 of this Article1, 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 State, if: (a) the The recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12twelve-month period commencing or ending in the fiscal year concerned; and (b) the The remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the 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 preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 18 and 21 of this Agreement19, salaries, wages and other similar remuneration derived by an individual who is 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 from that exercise may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by an individual who is 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 firstmentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-12 month period commencing or ending in the fiscal year concernedof income or year of assessment of that other State; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) the remuneration is not borne by deductible in determining taxable profits of a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 and 21 of this Agreement20, salaries, wages and other similar remuneration derived by an individual who is a resident of a one of the Contracting State States 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 of this Article1, remuneration derived by an individual who is a resident of a one of the Contracting State States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if:if - (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-month period commencing or ending in the year of income of fiscal year concernedyear, as the case may be, of that other State; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) the remuneration is not borne by deductible in determining the taxable profits of a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by a resident of one of the Contracting States may be taxed in the that Contracting State in which the place of effective management of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 17, 18, 19 19, 20 and 21 of this AgreementConvention, 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 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 Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-twelve month 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 a 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 or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1616 (Directors’ Fees), 1818 (Pensions), and 19 and 21 of this Agreement(Public Remuneration), salaries, wages 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 of this Article1, remuneration derived by a resident of a Contracting 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 182 183 days in any 12-month period commencing or ending in the fiscal year taxable period 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 a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard as a member of the regular complement of a ship or aircraft operated in international traffic may shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

DEPENDENT PERSONAL SERVICES. 1. 1 - Subject to the provisions of Articles (16), (18), 19 (19), (20) and 21 of this Agreement(21), 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 employ- ment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. 2 - Notwithstanding the provisions of paragraph 1 of this Article(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) a - the recipient is present in the other Contracting State for a period or periods not exceeding ex- ceeding in the aggregate 182 (183) days in any 12-twelve month period commencing com- mencing or ending in the fiscal year concerned; and (b) , 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) , and c - the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. 3 - Notwithstanding the preceding provisions of this Article, remuneration derived de- rived in respect of an employment exercised aboard a ship or aircraft operated oper- ated in international traffic by an enterprise of a Contracting State may be taxed in the that Contracting State in which the place of effective management of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 1819, 19 20 and 21 of this Agreement21, salaries, wages and other similar remuneration derived by an individual who is a resident of a one of the Contracting State States 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 from that exercise may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 (1) of this Article, remuneration derived by an individual who is a resident of a one of the Contracting State States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if:if - (a) a. the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-month period commencing the year of income or ending in year of assessment, as the fiscal year concernedcase may be, of that other State; and (b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) c. the remuneration is not borne by deductible in determining taxable profits of a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by a resident of one of the Contracting States may be taxed in the that Contracting State in which the place of effective management of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21 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 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 Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 (one hundred and eighty three) days in any 12-12 (twelve) month 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 a 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 or aircraft operated in international traffic traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21 of this Agreement, salaries, wages and other similar remuneration derived by a resident of a Contracting State Party in respect of an employment shall be taxable only in that Contracting State Party unless the employment is exercised in the other Contracting StateParty. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting StateParty. 2. Notwithstanding the provisions of paragraph 1 of this Article, remuneration derived by a resident of a Contracting State Party in respect of an employment exercised in the other Contracting State Party shall be taxable only in the first-mentioned Contracting State Party if: (a) the recipient is present in the other Contracting State Party for a period or periods not exceeding in the aggregate 182 183 days in any 12twelve-month 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; Party, and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting StateParty. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may by an enterprise of a Contracting Party shall be taxed taxable only in the that Contracting State in which the place of effective management of the enterprise is situatedParty.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 17, 18, 19 19, 20 and 21 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 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 Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12twelve-month 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 a 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 or aircraft operated in international traffic may shall be taxed taxable only in the Contracting a State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21 of this Agreement21, 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 exercisedexercised in the other Contracting State, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 ifif all the following conditions are met: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-twelve month 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 a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship ship, aircraft, railway or aircraft road vehicle operated in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 and 21 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 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 Contracting State if: (a) a. the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 days in any 12-month period commencing or ending in the fiscal year concerned; and (b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) c. 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 preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21 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 there from may be taxed in that other Contracting 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 Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12twelve-month 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 a fixed base 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 or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the place of effective management of the enterprise is situated. 4. An individual who is a national of a Contracting State and is appointed from head office of national air carrier of a Contracting State to the other Contracting State shall be exempted from taxes levied on his remunerations in that other Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 17, 18, 19 and 21 of this Agreement20, salaries, wages and other similar remuneration derived by an individual who is a resident of a one of the Contracting State States 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 from that exercise may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 of this Article(1), remuneration derived by an individual who is a resident of a one of the Contracting State States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State ifif : (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-month period commencing or ending in the fiscal a year concerned; andof income of that other State; (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) the remuneration is not borne by deductible in determining taxable profits of a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding Notwithstanding, the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by a resident of one of the Contracting States may be taxed in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21 of this Agreement21, 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 there- from may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 The resident is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12twelve-month period commencing or ending in the fiscal year concerned; and; (b) the The remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and; (c) the The remuneration is not borne by a permanent establishment or a fixed base base, which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect re- spect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1616 (Directors’ fees), 18, 18 (Pensions) and 19 and 21 of this Agreement(Government service), 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 of this Article1, 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 first­mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, a person being an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which that the person being an 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 or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the place of effective management of the enterprise is situatedby that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 and 21 of this Agreement20, salaries, wages and other similar remuneration derived by an individual who is a resident of a one of the Contracting State States 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 from that exercise may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by an individual who is a resident of a one of the Contracting State States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if:if - (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-month period commencing the year of income or ending in taxable year, as the fiscal year concernedcase may be, of that other State; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) the remuneration is not borne by deductible in determining taxable profits of a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by a resident of one of the Contracting States may be taxed in the that Contracting State in which the place of effective management of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 and 21 of this Agreement20, salaries, wages and other similar remuneration derived by an individual who is a resident of a one of the Contracting State States 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 of this Article1, remuneration derived by an individual who is a resident of a one of the Contracting State States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if:if - (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-month period commencing or ending in the year of income of fiscal year concernedyear, as the case may be, of that other State; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) the remuneration is not borne by deduct ible in determining the taxable profits of a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by a resident of one of the Contracting States may be taxed in the that Contracting State in which the place of effective management of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1616 (Directors' fees), 1818 (Pensions), and 19 and 21 of this Agreement(Public remuneration), salaries, wages 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 of this Article1, 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 182 183 days in any 12-month period commencing or ending in the fiscal year taxable period 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 a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard as a member of the regular complement of a ship or aircraft operated in international traffic may shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

DEPENDENT PERSONAL SERVICES. 1. ) Subject to the provisions of Articles 16, 18, 19 and 21 of this Agreement20, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment em- ployment 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 of this Articlepara- graph 1, remuneration derived by a resident resi- dent 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 excee- ding in the aggregate 182 183 days in any 12-month period commencing or ending en- ding in the fiscal year concerned; and (• b) the remuneration is paid by, or or, on behalf of, of an employer who is not a resident re- sident of the other Contracting State; and (• c) the remuneration is not borne by a permanent establishment or a fixed base ba- se which the employer has in the other Contracting State. 3. ) Notwithstanding the preceding provisions provi- sions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international inter- national traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21 of this AgreementConvention, 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 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 Contracting State if: (a) a. the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-twelve month period commencing or ending in the fiscal taxable year concerned; and; (b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the that Contracting State in which the place of effective management of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21 of this AgreementConvention, 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 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 Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12twelve-month 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 a 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 or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21 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 there from may be taxed in that other Contracting 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 Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12twelve-month 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 a fixed base 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 or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 1617, 1819, 19 20 and 21 of this Agreement21, salaries, wages and other similar remuneration derived by an individual who is a resident of a one of the Contracting State States 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 from that exercise may be taxed in that other Contracting State. (2. ) Notwithstanding the provisions of paragraph 1 (1) of this Article, remuneration derived by an individual who is a resident of a one of the Contracting State States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if:if - (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 182 183 days in any 12-month period commencing the year of income or ending in year of assessment, as the fiscal year concernedcase may be, of that other State; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; and (c) the remuneration is not borne by deductible in determining taxable profits of a permanent establishment or a fixed base which the employer has in the that other Contracting State. (3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by a resident of one of the Contracting States may be taxed in the that Contracting State in which the place of effective management of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1616 (Directors' Fees), 18, 18 (Pensions and Annuities) and 19 and 21 of this Agreement(Government Service), 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, exercised such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 182 183 days in any 12twelve-month period commencing or ending in the fiscal year concerned; and (b) the remuneration is paid by, by or on behalf of, 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 a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard as a member of the complement of a ship or aircraft operated in international traffic may be taxed only in the Contracting State in which the place of effective management of the enterprise is situatedthat State.