Common use of DEPENDENT PERSONAL SERVICES Clause in Contracts

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 (one hundred eighty three) days in any twelve-month period commencing or ending in the taxable 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 may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 and 19, 20, 21 and 22 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 (one hundred eighty three) days in any twelve-month period commencing the basis year or ending in the taxable relevant year concernedof income, as the case may be; 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 resident of the other Contracting State 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 may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, 19 and 19, 21 salaries, wages wages, gratuities and other similar remuneration derived by an individual who is a resident of a one of the Contracting State States in respect of an employment shall be taxable only in that 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 an individual who is a resident of a one of the Contracting State States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the that other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-month period commencing or ending in the taxable year concerned, calendar year; 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 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 one of the Contracting State may States shall be taxed taxable only in that Contracting State.

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 Contracting State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-month period commencing or ending in the taxable 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 may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by an individual who is a resident of a Contracting State in respect of an employment shall be taxable only in that 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 an individual who is a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve12-month period commencing or ending in the taxable 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 may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18 and 19, salaries, wages and other similar remuneration derived by an individual who is a resident of a one of the Contracting State States in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom from that exercise may be taxed in that other State. (2. ) Notwithstanding the provisions of paragraph (1), remuneration derived by an individual who is a resident of a one of the Contracting State States in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned firstmentioned State if: (a) the recipient is present in the that other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-month period commencing or ending in the taxable year concerned, andof income of that other State; (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other State; and (c) the remuneration is not borne by deductible in determining taxable profits of a permanent establishment or a fixed base which the employer has in the that other 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 one of the Contracting State States may be taxed in that Contracting State.

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 ifif each of the following conditions is met: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-twelve month period commencing or ending in the taxable 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 may be taxed in that Contracting State.

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 Contracting State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-twelve month period commencing or ending in the taxable 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 ship, aircraft or aircraft road vehicle operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 19, 20 and 1921 of this Agreement, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned firstmentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-twelve month period commencing or ending in the taxable 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 may shall be taxed taxable only in that Contracting State.

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 State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-month period commencing or ending in the taxable 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 may State, shall be taxed taxable only in that Contracting State.

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-first- mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in within any twelve-month period commencing falling wholly or ending in partly within the taxable fiscal year concernedconcerned of that other State, and (b) 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 remuneration is not borne by a permanent establishment or a fixed base which the employer person 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 may be taxed in that the Contracting StateState in which the place of effective management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18 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 ifif : (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-twelve month period commencing or ending in the taxable fiscal year concerned, and; ] (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other StateState ; 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 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 may be taxed in that Contracting State.

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-first- mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-month period commencing or ending in the taxable 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 may State, shall be taxed taxable only in that Contracting State.

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-first- mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-twelve month period commencing or ending in the taxable 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 may be taxed in that the Contracting StateState in which the place of effective management of the enterprise is situated.

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 Contracting State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-twelve month period commencing or ending in the taxable fiscal year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the that other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise of a Contracting State may be taxed in that Contracting State.

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 (one hundred eighty three) days in any twelve-month period commencing or ending in the taxable tax year concerned, andconcerned of that other State, (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 may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 18, and 19, wages, 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 solely in the first-mentioned State if: (a) the recipient is not present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in during any twelve-month period commencing or ending in the taxable fiscal year concernedin question, 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 a person has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may only be taxed in that Contracting State.

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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-first- mentioned Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-twelve month period commencing or ending in the taxable year concerned, and; (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.. Article 16‌‌‌

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-first- mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-month period commencing or ending in the taxable 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 from an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that the Contracting StateState in which the place of effective management of the enterprise is situated.

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 11 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in within any twelve-month period commencing falling wholly or ending in partly within the taxable fiscal year concernedconcerned 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 State, may be taxed in that Contracting State.

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 11 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State State, for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) and eighty-three days in any twelve-twelve month period commencing or ending in the taxable 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 the other Contracting State may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject Without prejudice to the provisions of Articles 16, 18 17, 18, and 19, salaries, wages and other types of similar remuneration derived received by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the such employment is exercised in the other Contracting State. If In case the employment is so exercised, such remuneration as is derived therefrom may received therefor can be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived obtained 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 (one hundred eighty three) and eighty-three days in during any twelve-month period commencing or ending during the fiscal year in the taxable year concernedquestion, 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 place of business which the employer has in the other State. 3. Notwithstanding the The preceding provisions of this ArticleArticle notwithstanding, remuneration derived obtained in respect of an employment exercised aboard a ship or aircraft operated by an enterprise in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.

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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any the twelve-month period commencing or ending in the taxable year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship ship, boat or aircraft operated in international traffic by an enterprise of a Contracting State State, may be taxed in that Contracting State.

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 (one hundred eighty three) days in within any twelve-month period commencing or ending in the taxable 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 may be taxed in that Contracting State.

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 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 11 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-month period commencing or ending in the taxable 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 may State, shall be taxed taxable only in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 17, 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 State, if: (a) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any twelve-month period commencing the relevant "previous year" or ending in "year of income", as the taxable year concerned, case may be; 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 may shall be taxed taxable only in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1620 (Pensions, 18 Annuities, Alimony, and 19Child Support) and 21 (Government Service), salaries, wages wages, and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 (one hundred eighty three) days in any twelve-12 month period commencing or ending in the taxable year concerned, andperiod; (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 as a member of the regular complement of a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18 and 18, 19, and 20 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in within any twelve-month period commencing or ending in the taxable 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, may be taxed in that Contracting State.

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 (one hundred eighty threethree (183) days in any twelve-twelve (12) month period commencing or ending in the taxable 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 from an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject Without prejudice to the provisions of Articles 16, 18 17, 18, and 19, salaries, wages and other types of similar remuneration derived received by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the such employment is exercised in the other Contracting State. If In case the employment is so exercised, such remuneration as is derived therefrom may received therefor can be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived obtained 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 (one hundred eighty three) and eighty-three days in during any twelve-month period commencing or ending during the fiscal year in the taxable year concernedquestion, 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 place of business which the employer has in the other State. 3. Notwithstanding the The preceding provisions of this ArticleArticle notwithstanding, remuneration derived obtained in respect of an employment exercised aboard a ship or aircraft operated by an enterprise in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.