DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 10 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18 18, 19 and 19, 20 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
(2. ) Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
(3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 7 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 1617, 18 19, 20, 21 and 1922, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
(2. ) Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
(3. ) Notwithstanding the preceding provisions of this Article, Article remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 5 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 5 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 4 contracts
Samples: Income Tax Agreement, Convention to Avoid Double Taxation, Double Taxation Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 4 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Elimination of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base base, which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State. However, if the remuneration is derived by a resident of the other Contracting State, it may also be taxed in that other State.
Appears in 4 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 3 contracts
Samples: Income Tax Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and;
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall State, may be taxable only taxed in that State.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 3 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
(2. ) Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
(3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall State, may be taxable only taxed in that State.
Appears in 3 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1618, 18 19, 20, 21, 22 and 1923, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, exercised such remuneration as is derived therefrom there from may be taxed in that other 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 State if:
(a) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar relevant year concerned; of income, and
(b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 3 contracts
Samples: Double Taxation Agreement, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; any twelve-month period, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
(2. ) Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
(3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Stateof which the operator is a resident.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16l6, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be maybe taxed in that other 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 State if:β
(a) the recipient is present in the that other State for a period or periods not exceeding in the aggregate 183 days in the calendar 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 State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base base, which the employer has in the other State.
(3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State State, shall be taxable only in that State.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concernedwithin 12 month period; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft or road vehicle operated in international traffic by an enterprise of a Contracting State shall in international traffic may be taxable only taxed in that State.
Appears in 2 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 18, 19, 20 and 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 State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; within any twelve- month period, and
(b) the remuneration is paid by, or on an behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of or this Article, remuneration derived in respect of an employment exercised aboard a ship vessel or aircraft or vehicle operated in international traffic traffic, by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, exercised such remuneration as is derived therefrom may be taxed in that other 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 State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer employer, who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an a employment exercised aboard a ship or an aircraft operated in international traffic by an enterprise a resident of a one of the Contracting State shall States may be taxable only taxed in that Contracting State.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concernedany twelve-month period; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 2 contracts
Samples: Income Tax Convention, Income and Property Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; any twelve month period, and
(b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:if:β
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that Contracting State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Income Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first---mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar tax year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State State, shall be taxable only in that State.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concernedwithin any twelve month period; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 19 and 1920, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated operation in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) c. the remuneration is not borne by a resident or a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only in that State.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 18, 19, 20 and 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 State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, Article remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 2 contracts
Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 16,18,19,20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base base, which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 2 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State State, unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present remains in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; andrelevant fiscal year;
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall State, may be taxable only taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Tax Treaty
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16XVI, 18 XVIII and 19XIX, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, 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 State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State State, shall be taxable only in that State.
Appears in 1 contract
Samples: Income Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, salaries wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 90 days in the calendar year concernedany twelve-month period; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1615, 18 17, 18, 27 and 1928 of this Convention, salaries, wages and other similar remuneration derived by a resident of a Contracting State one of the States in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State one of the States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar 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 State; , and
(c) the The remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of one of the States in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1615, 18 17 and 1918, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, 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 State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles articles 16, 18 and 19, salaries, 19 salaries wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State 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 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 State if:if -
(a) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concernedwithin any period of twelve months; and
(b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other 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 State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Tax Treaty
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19 and 1920, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, 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 State ifif :
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; within any period of twelve months, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall in international traffic, may be taxable only taxed in that State.
Appears in 1 contract
Samples: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding Nothwithstanding 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 State if:
(a) the The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the The remuneration is paid by, or on behalf of, an employer a person who is not a resident of the other State; , and
(c) the The remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other 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 by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Income and Capital Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, 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 the State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State State, shall be taxable only in that State.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16XVI, 18 XVIII, XIX and 19XX, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other 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 State if:
(a) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable taxed only in that State.
Appears in 1 contract
Samples: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and
(b) the The remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the The remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other 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 by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Income and Capital Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State ifif :
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; andrelevant fiscal year;
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall State, may be taxable only based in that State.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation of Income and the Prevention of Fiscal Evasion
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20, and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, 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 State State, if:
(a) the recipient is present in the that other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concernedwithin any period of 12 months; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 1 contract
Samples: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State one of the States in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State one of the States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State ifif :
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of one of the States in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, shall be taxable only in that State.
Appears in 1 contract
Samples: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18 19 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
(2. ) Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
(3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Double Taxation Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State State, unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 120 days in the calendar fiscal year concerned; and;
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
(2. ) Notwithstanding the provisions of paragraph (1), remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:if--
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
(3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Income and Capital Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles articles 16, 18 and 19, salaries, 19 salaries wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State state unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 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 State if:if -
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concernedwithin any period of twelve months; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other 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 State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Tax Treaty
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1618, 18 20, 21, 22 and 1923, salaries, wages and other similar remuneration derived by a resident of a Contracting State one of the States in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State one of the States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State State, if:
(a) the recipient is present in the that other State for a period or periods not exceeding in the aggregate 183 days in the calendar 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 State; , and
(c) the remuneration is not borne as such by a permanent establishment or a fixed base which the employer has in the that other 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 by an may be taxed in the State in which the place of effective management of the enterprise of a Contracting State shall be taxable only in that Stateis situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 16,18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, exercised such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding Not withstanding 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 State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an and employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, salaries wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 90 days in the calendar year concernedany twelve- month period; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) 3. the remuneration is not borne by a x permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 1 contract
Samples: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19 and 1920, salaries, wages and other similar remuneration derived by a resident of person domiciled in a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of person domiciled in a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-first- mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; any consecutive twelve-month period, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of domiciled in the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an may be taxed in the State in which the place of effective management of the enterprise of a Contracting State shall be taxable only in that Stateis situated.
Appears in 1 contract
Samples: Income and Capital Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1615, 18 17 and 1918, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.,
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of enterprise is situated.
Appears in 1 contract
Samples: Double Taxation Treaty
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles Article 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Income Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that Contracting State.
Appears in 1 contract
Samples: Income Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall in international traffic, may be taxable only taxed in that Contracting State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concernedany twelve month period; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship ship, boat or aircraft aircraft, or road vehicle operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concernedany 12 month period; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise a resident of a Contracting State shall may be taxable only taxed in that State.
Appears in 1 contract
Samples: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable is exercisable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other 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 State if:
(a) the a. The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concernedwithin any 12 month period; and
(b) b. the remuneration renumeration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the c. that remuneration is not borne borne, by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, Article remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed only in the Contracting State shall be taxable only in that Statewhich the place effective management of the enterprise is situated.
Appears in 1 contract
Samples: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in during the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the cost of the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Income and Capital Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19 and 1920, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, 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 State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; concerned of that other State, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that Contracting State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
(2. ) Notwithstanding the provisions of paragraph (1), remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
(3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. ) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration remu- neration as is derived therefrom there from may be taxed in that other 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 State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Income Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; any twelve months period, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship ship, boat or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable taxed only in that Contracting State.
Appears in 1 contract
Samples: Income and Capital Tax Treaty
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles Articles, 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. ) Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. ) Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(ai) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(bii) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(ciii) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 1 contract
Samples: Income Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 19, 20, 21 and 1922, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise which is a resident of a Contracting State shall be taxable only in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 19 and 1920, salaries, wages and other similar remuneration derived by a a. resident of a Contracting State one of the States in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1I of this article, remuneration derived by a resident of a Contracting State one of the States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-first mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; andof the year of assessment.
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an may be taxed in the State of which the enterprise of is a Contracting State shall be taxable only in that Stateresident.
Appears in 1 contract
Samples: Double Taxation Relief Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 19, 20, 21 and 1922, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable taxed only in that State.
Appears in 1 contract
Samples: Income Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 17, 18, 19 and 19, 20 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer employee who is not a resident of the that other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the that other 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 by an enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 1 contract
Samples: Double Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 and 18, 19, 20 and 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 State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, 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 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 the calendar year concernedany period of twelve months; and
(b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other contracting State.
3. Notwithstanding the preceding provisions of this Article, the remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an the enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 1 contract
Samples: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the that other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 1 contract
Samples: Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State State, shall be taxable only in that State.
Appears in 1 contract
Samples: Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 19, and 1920, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concernedany twelve-month period; and
(b) the The remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the The remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State State, shall be taxable only in that State.
Appears in 1 contract
Samples: Tax Treaty
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, by or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, Article remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph (1), remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or of periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(b) the remuneration is paid paid, by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
Samples: Convention to Avoid Double Taxation and Prevent Fiscal Evasion
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) 1. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the calendar fiscal year concerned; , and
(b) 2. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) 3. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 19, 20, 21 and 1922, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other 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 State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard abroad a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 1 contract
Samples: Income Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 1918, 19 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, or on behalf ofof , an employer who is not a resident of the other State; Sate, and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; , and
(b) the The remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the The remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other 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 by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; any twelve month period, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; within any twelve-month period, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise a resident of a Contracting State shall be taxable only in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles articles 16, 18 and 18, 19, salaries20 and 21, wages wages, salaries and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State State, unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar 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 State; and
(c) the Such remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other 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 by an enterprise of a may be taxed in the Contracting State shall be taxable only in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles Article 16, 18 18, 19 and 1920, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other 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 State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; within any twelve-month period, and
(b) the remuneration is paid by, or on behalf of, by an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by an enterprise of the other State or by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 1 contract
Samples: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, 19 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, 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 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 the calendar year concerned; andrelevant fiscal year;
(b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other 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 by an enterprise of a Contracting State shall State, may be taxable only taxed in that State.
Appears in 1 contract
Samples: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19, 20 and 1921, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar fiscal year concerned; , and
(b) the remuneration is paid by, by or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, Article remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19 and 1920, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar taxable year concerned; and, and either
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and, or
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State State, shall be taxable only in that State.
Appears in 1 contract
