Common use of DEPENDENT PERSONAL SERVICES Clause in Contracts

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 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 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 enterprise operating the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 de- rived therefrom may be taxed in that other Contracting State. (2) . Notwithstanding the provisions of paragraph 1, remuneration derived by a resident resi- dent of a Contracting State in respect of an employment exercised in the other Contracting Contract- ing 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 ex- ceeding in the aggregate 183 days in any twelve month period commencing commenc- ing 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 res- ident 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 may be taxed in the Contracting State in which the place of effective manage- ment of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 period of twelve month period months commencing or ending in the fiscal calendar year concerned, ; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other first-mentioned 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 traffic shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve month period commencing or ending in the fiscal calendar 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 traffic by a resident of a Contracting State shall be taxable only in which the enterprise operating the ship or aircraft is a residentthat Contracting State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 18 and 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 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 twelve twelve-month period commencing or ending in the fiscal calendar 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 traffic shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise operating is situated. However, if the ship or aircraft remuneration is derived by a residentresident of the other Contracting State, it may also be taxed in that other Contracting State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 17, 18, 19, 20 and 2021, salaries, wages and other similar simliar 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 twelve month period commencing or ending in the fiscal calendar 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 of which the enterprise operating the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 18 and 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 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.. Articles 15, 16 and 17 (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 The recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve twelve-month period commencing com- mencing 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 remunera- tion derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, or aboard a boat engaged in inland water- ways transport, may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 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 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 resident is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve 12-month period commencing or ending in the fiscal calendar 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 traffic by an enterprise of a Contracting State shall be taxable only in which the enterprise operating the ship or aircraft is a residentthat Contracting State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 provisiona 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 firstmentioned 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 twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise of a Contracting State in international traffic, may shall be taxed taxable only in the Contracting State in which the place of head affice (i.e. effective management) of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 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 twelve month period commencing or ending in the fiscal calendar 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 State in which the place of head office (place of effective management) of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 19 and 2021 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 11 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 183 182 days in any twelve 12-month period commencing or ending in the fiscal year concerned, and b) ; and the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State, and c) ; and 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 may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 20, 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 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 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 twelve month period commencing or ending in the fiscal calendar 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 by an enterprise of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 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 11 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 183 days in any twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise which is a resident of a Contracting State in international traffic, may shall be taxed taxable only in the that Contracting State in which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16l6, 18l8, 19l9, 20 and 2021, 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 that other Contracting State for a period or periods not exceeding in the aggregate 183 days in within any twelve month period commencing or ending in the fiscal year concerned, period; 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 traffic by an enterprise of a Contracting State shall be taxable only in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 within any twelve month period commencing or ending in the fiscal year concerned, period; 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 traffic by an enterprise of a Contracting State shall be taxable only in which the enterprise operating the ship or aircraft is a residentthat Contracting State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 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 1paragraph1, 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 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 shall be taxed taxable only in the Contracting State in which the enterprise operating the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 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 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 within any twelve month period commencing or ending in the fiscal year concerned, of 12 months; 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise which is a resident of a Contracting State in international traffic, may shall be taxed taxable only in the that Contracting State in which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve 12-month period commencing or ending in the fiscal year concerned, period; 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 paragraphs 1 and 2 of this Articlearticle, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise which is a resident of a Contracting State in international traffic, may shall be taxed taxable only in the that Contracting State in which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 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 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 paragraphs 1 and 2 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 by an enterprise which is a resident of a Contracting State in which the enterprise operating the ship or aircraft is a residentinternational traffic shall be taxable only in that Contracting State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 19 and 20, 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 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 period of twelve month period consecutive months 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 or aircraft operated in international traffic, may traffic shall be taxed taxable only in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 11 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 The recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve twelve-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, 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 operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 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 one hundred and eighty three (183) days in any 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 shall be taxed taxable only in the Contracting State in of which the enterprise operating the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 16,18,19,20 and 20, salaries, 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 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, 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-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 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 of which the enterprise operating the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 11 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 183 days in any 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 may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 resident is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal calendar 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 traffic by an enterprise of a Contracting State shall be taxable only in which the enterprise operating the ship or aircraft is a residentthat Contracting State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 11 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 The recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve twelve-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, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State in which the enterprise operating profits from the operation of the ship or aircraft is a residentare taxable according to the provisions of Article 8.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve month period commencing or ending in the fiscal calendar 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 (i. e. head office) of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20, 21, 22 and 2023, 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-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 183 days in any twelve month period commencing or ending in the relevant fiscal year concernedyear, and b) b. the remuneration is paid by, or on behalf of, 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 Articlearticle, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, may be taxed in the traffic by an enterprise of a Contracting State shall be taxable only in which that Contracting State. In case of aircraft, the term "enterprise operating of a Contracting State" shall have the ship or aircraft is a residentsame meaning as defined in paragraph 5 of Article 8 of this Agreement.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship ship, aircraft or aircraft land vehicle operated by an enterprise of a Contracting State in international traffic, may shall be taxed taxable only in the Contracting State in which the place of head office of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 18 and 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 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, 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 (one hundred eighty three) days in any twelve month twelve-months 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 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 from an employment exercised aboard a ship or aircraft operated in international traffic, traffic may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 1615, 17, 18, 19, 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 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 ifState: if the three following conditions are simultaneously met: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal calendar 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 Articleparagraphs 1 and 2, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, traffic by an enterprise of a Contracting State may be taxed in the that Contracting State in which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise which is a resident of a Contracting State in international traffic, may shall be taxed taxable only in the that Contracting State in which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 11 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 The recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve twelve-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, may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 firstmentioned Contracting State State, if: (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal calendar 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 Articleparagraphs 1 and 2, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, traffic by an enterprise of a Contracting State may be taxed in the that Contracting State in which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise of a Contracting State in international traffic, may shall be taxed taxable only in the Contracting State in which the place of head office or effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 19 and 20, 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, 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 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 twelve 12 month period commencing or ending in the fiscal year concerned, of income 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 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, traffic may be taxed in the Contracting State in of which the enterprise operating the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 19 and 2021 of this Convention, 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 11 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 183 days in any twelve 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 operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 19 and 2020 of this Convention, 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 11 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 183 days in any twelve month period commencing or ending in the fiscal year concernedconcerned of the other State, 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 traffictraffic by an enterprise of a Contracting State, may be taxed in the that Contracting State in which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 16,18,19,20 and 20, salaries, wages 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 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 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-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 twelve month period commencing or ending in the fiscal year concerned, 365 day period; 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, other than a ship or aircraft operated solely between places in international trafficone Contracting State, may be taxed taxable in the Contracting State in of which the enterprise operating employer is a resident. Where the employment is exercised aboard a ship or aircraft is a residentoperated solely between places in one Contracting State paragraphs 1 and 2 shall apply.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 11 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 The recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve twelve-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 ship, an aircraft or aircraft a road vehicle operated in international traffic, may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 18 and 2019 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 11 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 183 days in any twelve 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 an aircraft operated in international traffic, traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 18 and 19, and 20, 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, remuneration derived by a resident resi- dent of a Contracting State in respect of an employment exercised in the other Contracting Con- tracting State shall be taxable only in the first-mentioned Contracting State if: a) the The recipient is present in the other Contracting State for a period or periods not exceeding ex- ceeding in the aggregate 183 days in any twelve twelve-month period commencing commenc- ing 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 res- ident 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 of an employment exercised aboard a ship or aircraft operated in international traffic, traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 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 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 twelve twelve-month period commencing or ending in the fiscal year concerned, period; 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 by an enterprise of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 11 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 183 days in any twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise of a Contracting State in international traffic, may shall be taxed taxable only in the Contracting State in which the place of effective management of the business of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 16,18,19,20 and 20, 21 salaries, wages and other similar remuneration remuneration, other than a pension, 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 ifif : a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in within any twelve twelve-month period commencing or ending in the fiscal year concernedperiod, 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 traffic by an enterprise of a Contracting State shall be taxable only in which that State. Where a resident of Sweden derives remuneration in respect of an employment exercised aboard an aircraft operated in international traffic by the enterprise operating the ship or aircraft is a residentair transport consortium Scandinavian Articles System (SAS), such remuneration shall be taxable only in Sweden.

DEPENDENT PERSONAL SERVICES. (1) Subject to the provisions of Articles 16, 17, 18, 19, 19 and 2020 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 ifif : (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in within any continuous period of twelve month period commencing or ending in the fiscal year concerned, months; 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 may be taxed in the Contracting State in of which the enterprise operating person deriving the profits from the operation of the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise of a Contracting State in international traffic, may be taxed in the Contracting State in which the place of head office (i.e. effective management) of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 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 11 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-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 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 traffictraffic by an enterprise of a Contracting State, may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 19 and 2021 of this Convention, 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 11 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 183 days in any twelve 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, traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 17, 18, 19, 20 and 2021, 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-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 twelve month period commencing the relevant “previous year” or ending in “tax year” concerned, as the fiscal year concernedcase may be, 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 an enterprise of the other Contracting State or 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 rmuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, may be taxed in the by an enterprise of a Contracting State shall be taxable only in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 183 days in any twelve 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 by an enterprise of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 17, 18, 19, 20 and 2021, 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 twelve month period commencing the relevant "previous year" or ending in "year of income", as the fiscal year concerned, case may be ; and (b) the remuneration is paid by, or on behalf ofon, an employer who is not a resident of the other Contracting State, 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 traffic by an enterprise of a Contracting State shall be taxable only in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise of a Contracting State in international traffic, may shall be taxed taxable only in the Contracting State in which the place of head office of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 18 and 2019 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 11 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 183 days in any twelve 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 operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) Subject to the provisions of Articles 16, 18, 19, 19 and 2020 of this Convention, 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 183 days in any 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 or aircraft operated in international traffic, may traffic shall be taxed taxable only in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 de- rived therefrom may be taxed in that other Contracting State. (2) . Notwithstanding the provisions of paragraph 1, remuneration derived by a resident resi- dent of a Contracting State in respect of an employment exercised in the other Contracting Contract- ing 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 exceed- ing in the aggregate 183 days in any 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 resi- dent 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 may be taxed in the Contracting State in which the place of effective manage- ment of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 18 and 19, and 20, 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 de- rived therefrom may be taxed in that other Contracting State. (2) . Notwithstanding the provisions of paragraph 1, remuneration derived by a resident resi- dent of a Contracting State in respect of an employment exercised in the other Contracting Contract- ing 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 ex- ceeding in the aggregate 183 days in any twelve month period commencing commenc- ing 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 res- ident 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 by an enterprise of a Contracting State may be taxed in the that Contracting State in which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 17, 18, 19, 20 and 2021, 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 period of twelve month period commencing or ending in the fiscal year concerned, months; 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 traffictraffic by an enterprise of a Contracting State, may be taxed in the Contracting State in which the place of head office (i. e. effective management) of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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, 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 twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise of a Contracting State in international traffic, may shall be taxed taxable only in the Contracting State in which the place of head office of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise of a Contracting State in international traffic, may shall be taxed taxable only in the Contracting State in which the place of head office (i. e. effective management) of the employing enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 1617, 18, 19, 19 and 20, 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, 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 State if: (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve 12 month period commencing or ending in the fiscal year of income 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 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, traffic by a resident of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 11 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 The recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve twelve- 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 ship, an aircraft or aircraft a road vehicle operated in international traffic, may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 taxble 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 twelve month period commencing or ending in the fiscal calender 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, traffic may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 20, 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 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 remuncration 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 period, or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal taxable 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic, may be taxed in the traffic by an enterprise of a Contracting State shall be taxable only in which the enterprise operating the ship or aircraft is a residentthat Contracting State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles articles 16, 18, 18 and 19, and 20, salaries, wages and other similar remuneration derived by a resident of a Contracting Con- tracting State in respect of an employment shall be taxable only in that Contracting State unless the employment is exercised in the other Contracting Con- tracting 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 employ- ment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if: (a) the The recipient is present in the other Contracting State for a period or periods peri- ods not exceeding in the aggregate 183 days in any twelve twelve-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 Articlearticle, remuneration re- muneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, or aboard a boat en- gaged in inland waterways transport, may be taxed in the Contracting ARTICLES 15, 16 AND 17 State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles Article 16, 18, 19, 19 and 2020 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 State, if: a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 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 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 other Contracting State. (3) . Notwithstanding the preceding provisions of this Article, remuneration derived paid by an enterprise of a Contracting State in respect of an employment exercised aboard a ship or aircraft operated in international traffic, may shall be taxed only in the that Contracting State in which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16Article 16 (Director’s Fees), 18, 19, 18 (Pensions) and 2019 (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, 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 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 an aircraft operated in international traffic, traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 20, 21 of this Convention 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 11of 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 183 days in any twelve 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 traffic by an enterprise of a Contracting State shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 17 and 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 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 Article, remuneration derived by a resident of in 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:if – (a) the recipient is present in the other Contracting State for a period periods or periods not exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the fiscal year concerned, period; 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, may be taxed in the Contracting State in of which the enterprise operating person deriving the profits from the operation of the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 1615, 17, 18, 19, 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 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 twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise which is a resident of a Contracting State in international traffic, may shall be taxed taxable only in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 19 and 20, 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 de- rived 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 exceed- ing in the aggregate 183 days in any 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 resi- dent 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 may be taxed in the Contracting State in which the place of effective manage- ment of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) Subject to the provisions of Articles 16, 18, 19, 19 and 2020 of this Convention, 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 183 days in any twelve 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 may be taxed in the Contracting State in of which the enterprise operating the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 11 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 183 days in within any twelve twelve-month period commencing or ending in the fiscal year concernedperiod, 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 traffic by an enterprise of a Contracting State shall be taxable only in which the enterprise operating the ship or aircraft is a residentthat Contracting State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 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 by an enterprise of a Contracting State in which the enterprise operating the ship or aircraft is a residentinternational traffic shall be taxable only in that Contracting State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 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 11 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 183 days in any twelve 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 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 ship, aircraft 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 operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20, 21, 22 and 2023, 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 twelve month period commencing or ending in the relevant fiscal year concernedyear, and (b) the remuneration is paid 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic, may be taxed in the traffic by an enterprise of a Contracting State shall be taxable only in which that Contracting State. In case of aircraft, the term "enterprise operating of a Contracting State" shall have the ship or aircraft is a residentsame meaning as defined in paragraph 5 of Article 8 of this Agreement.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 20, 21 of this Convention 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 11 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 The recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve 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 may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 18 and 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 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 (one hundred eighty three) days in any twelve 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 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 from an employment exercised aboard a ship or aircraft operated in international traffic, traffic may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 resident is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal calendar 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 traffic by an enterprise of a Contracting State shall be taxed taxable only in that Contracting State. 4. Ground staff appointed from head office of national air carrier of a Contracting State to the other Contracting State and who are nationals of that Contracting State shall be exempted from taxes levied on their remunerations in the other Contracting State in which the enterprise operating the ship or aircraft is a residentStates.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, . 18 and 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 Contracting State unless the employment is exercised in the other Contracting StateSlate. 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 1I, 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 (one hundred eighty three) days in any twelve 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 other Contracting State, Slate; 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 on board a ship or aircraft operated in international traffic, may be taxed in the Contracting State in which the enterprise operating profits from the ship operation of the ships or aircraft is a residentare taxable according to the provisions of Article 8.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 11 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 183 days in any 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 of which the enterprise operating the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) Subject to the provisions of Articles 16, 17, 18, 19, 19 and 20, 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), 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 firstmentioned State if: (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve 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 the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, traffic by a resident of one of the Contracting States may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve month consecutive period commencing or ending in the fiscal year concerned, of 12 months; 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 head office of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 11 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 183 days in any twelve 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, 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 operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 1818,19, 19, 20 and 2021, 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 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 183 days in any twelve month period commencing or ending in the fiscal calendar 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 Articleparagraphs 1 and 2, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, traffic by an enterprise of a Contracting State may be taxed in the that Contracting State in which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 17, 18, 19, 20 and 2021 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 11 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-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 twelve 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 traffic shall be taxed taxable only in the Contracting a State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 1616 (Directors' Fees), 18, 19, 18 (Pensions) and 2019 (Government Services), 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 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 an aircraft operated in international traffic, traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 11 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 a. The recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the fiscal year concerned, ; and b) the 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 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 ship, an aircraft or aircraft a road vehicle operated in international traffic, may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021, 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 twelve month period commencing or ending in the fiscal calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise of a Contracting State in international traffic, may shall be taxed taxable only in the Contracting State in which the place of head office or effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) Subject to the provisions of Articles 16, 17, 18, 19, 19 and 2020 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-first- mentioned Contracting State ifif : (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in within any continuous period of twelve month period commencing or ending in the fiscal year concerned, months; 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 may be taxed in the Contracting State in of which the enterprise operating person deriving the profits from the operation of the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 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 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 shall be taxed taxable only in the Contracting State in which the enterprise operating the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20, 21, 22 and 2023, 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 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-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 twelve month period commencing or ending in the relevant fiscal year concernedyear, and b) the remuneration is paid 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic, may be taxed in the traffic by an enterprise of a Contracting State shall be taxable only in which that Contracting State. In case of aircraft, the term “enterprise operating of a Contracting State” shall have the ship or aircraft is a residentsame meaning as defined in paragraph 5 of Article 8 of this Agreement.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 1817, 19, 20, 21 and 2022 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 11 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 183 days in any 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 by an enterprise of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 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 11 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 183 days in any twelve 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, traffic by an enterprise of a Contracting State may be taxed in that State. However, if the remuneration is derived by a resident of the other Contracting State State, it may also be taxed in which the enterprise operating the ship or aircraft is a residentthat other State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 19 and 2020 of this Convention, 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 11 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 183 days in any twelve twelve-month period commencing or ending in the fiscal year concerned, year; 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 may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated in accordance with Article 8 of this Convention.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 18 and 19, and 20, salaries, wages and other similar simi- lar 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 Con- tracting 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, remuneration derived by a resident resi- dent of a Contracting State in respect of an employment exercised in the other Contracting Contract- ing 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 twelve 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, traffic by a resident of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 1617, 18, 19, 20, 21 and 2022, 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 twelve month period commencing the relevant " previous year " or ending in " year of income ", as the fiscal year concernedcase may be, 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 abroad a ship or aircraft operated in international traffic, may traffic shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

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 s hall b e 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, 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 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 enterprise operating the ship or aircraft is a resident.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, 19, 20 and 2021 of this Convention, 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 11 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 The recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve twelve-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, may be taxed in the Contracting State in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. (1) . Subject to the provisions of Articles 16, 18, and 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 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, 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 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 by an enterprise of a Contracting State may be taxed in the Contracting State in which the enterprise operating the ship or aircraft is a residentthat State.