Common use of INCOME FROM EMPLOYMENT Clause in Contracts

INCOME FROM EMPLOYMENT. (1) Subject to the provisions of Articles 15, 17, 18, 19 and 20 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 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 any twelve month period commencing or ending in the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment 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 may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 1716, 18, 19 and 20 of this Agreement20, 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) of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the fiscal year concernedperiod; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. (3) . Notwithstanding the preceding provisions of this 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 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 the Contracting State in which the place of effective management of the enterprise is situatedthat other State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 17 and 20 18 of this AgreementConvention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 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 any twelve twelve-month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 may be taxed in the Contracting State in of which the place of effective management of enterprise operating the enterprise ship or aircraft is situateda resident.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 18 and 20 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 State. (2) . Notwithstanding the provisions of paragraph (1) 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 18 and 19 and 20 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 there from may be taxed in that other State. (2) . Notwithstanding the provisions of paragraph (1) 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 may by an enterprise of a Contracting State, shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 17 and 20 18 of this AgreementConvention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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) 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 18 and 19 and 20 of this AgreementConvention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 18 and 19 and 20 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 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) Subject to the provisions of Articles 15, 17, 18, 19 17 and 20 18 of this AgreementConvention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer being a person who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment which the employer 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 may shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 18 and 19 and 20 of this AgreementConvention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-first- mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concernedcalendar year; 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 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 may traffic, or aboard a boat, shall be taxed taxable only in the Contracting State in of which the place of effective management of enterprise operating the enterprise ship, boat or aircraft is situateda resident.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 18 and 20 of this Agreement20, 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 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 any twelve month period commencing or ending in the fiscal calendar year concerned; and (b) the remuneration is paid by, by or on behalf of, of an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment which the employer has in the other State. (3) . Notwithstanding the preceding provisions paragraphs of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 1716, 18, 19 19, 20 and 20 21 of this Agreement, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other 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 the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 17 and 18, 19 and 20 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 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 (one hundred eighty three) days in any twelve twelve-month period commencing or ending in the fiscal calendar year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 on board a ship or aircraft operated in international traffic may shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) Subject to the provisions of Articles 15, 17, 18, 19 17 and 20 18 of this AgreementConvention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 may be taxed in the Contracting State in of which the place of effective management of enterprise operating the enterprise ship or aircraft is situateda resident.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 18 and 20 of this Agreement19, 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 firstmentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment which the employer 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 may traffic, shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 and 20 of this Agreement20, 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 any twelve twelve-month period commencing or ending in the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment 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 may be taxed in the by an enterprise of a Contracting State shall be taxable only in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 1716, 18, 19 19, and 20 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 State. (2) . Notwithstanding the provisions of paragraph (1) 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other 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 may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 1716, 18, 19 and 20 of this Agreement20, 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 firstmentioned State ifif all the following conditions are met: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other 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, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 17 and 20 18 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 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other 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 paragraphs of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, may be taxed in the Contracting State in of which the place of effective management of enterprise operating the enterprise ship or aircraft is situateda resident.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 17 and 18, 19 and 20 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 exercisedexercised in the other Contracting State, 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-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 any period of twelve month period months commencing or ending in the fiscal calendar year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment which the employer 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 may shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 1716, 18, 19 19, and 20 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 State. (2) . Notwithstanding the provisions of paragraph (1) 1 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-first- mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other 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 may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 and 20 of this Agreement20, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other Contracting State. (2) . Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-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 any twelve a 12 month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment which the employer has in the other Contracting State. (3) . Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may by an enterprise of a Contracting State, shall be taxed taxable only in the that Contracting State in which the place of effective management of the enterprise is situatedState.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 18 and 20 of this Agreement20, 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 any twelve twelve-month period commencing or ending in the fiscal year concerned; and; (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment 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 may be taxed in the by an enterprise of a Contracting State shall be taxable only in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 18 and 20 of this Agreement20, 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 any twelve twelve-month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 may be taxed in the by an enterprise of a Contracting State shall be taxable only in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 1516, 17, 18, 19 and 20 of this Agreement20, 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-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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment which the employer 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 may traffic, shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 and 20 18 of this Agreementthe Convention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 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 any twelve month period commencing or ending in the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment which the employer 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 may (other than aboard a ship or aircraft operated solely within the other Contracting State) shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 and 20 of this Agreement20, 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-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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 may be taxed in the by a resident of a Contracting State shall be taxable only in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 17 and 18, 19 and 20 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 State. (2) . Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-first- mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 may by an enterprise of a Contracting State shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 17 and 18, 19 and 20 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 exercisedexercised in the other Contracting State, 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 any period of twelve month period months commencing or ending in the fiscal calendar year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment which the employer 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 may shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 and 20 of this Agreement20, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other Contracting State. (2) . Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve a 12 month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment which the employer has in the other Contracting State. (3) . Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may by an enterprise of a Contracting State, shall be taxed taxable only in the that Contracting State in which the place of effective management of the enterprise is situatedState.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 17 and 18, 19 and 20 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 exercisedexercised in the other Contracting State, such remuneration as is derived therefrom there from 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) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any period of twelve month period months commencing or ending in the fiscal calendar year concerned; and (b) 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 which the employer 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 may shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 17 and 18, 19 and 20 of this Agreement, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. (2) . Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment which the employer has in the other Contracting State. (3) . Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 18 and 19 and 20 of this AgreementConvention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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-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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 1716, 18, 19 19, 20 and 20 of this Agreement21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other 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 paragraphs of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the by an enterprise of a Contracting State shall be taxable only in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 18 and 19 and 20 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 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 only be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 1516, 17, 18, 18 and 19 and 20 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 State. (2) . Notwithstanding the provisions of paragraph (1) l 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other first-mentioned State; , and (c) the remuneration is not borne by a permanent establishment 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 the Contracting State in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 18 and 20 of this Agreement19, 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 any twelve month period commencing or ending in the fiscal calendar year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment 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, a boat, an aircraft or aircraft a road or rail transport vehicle operated in international traffic may by an enterprise of a Contracting State, shall be taxed taxable only in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 18 and 20 of this Agreement20, 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 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 any twelve month period commencing or ending in the fiscal calendar year concerned; and (b) the remuneration is paid by, by or on behalf of, of an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment which the employer has in the other State. (3) . Notwithstanding the preceding provisions paragraphs of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 17 and 18, 19 and 20 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 there from 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-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 any twelve month period commencing or ending in the fiscal year concerned; , and; (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 may by an enterprise of a Contracting State, shall be taxed taxable only in that State. 4. Ground staff appointed from head office of national air carrier of a Contracting State to the other Contracting State, and who were residents of the first-mentioned State before being stationed in the other Contracting State State, shall be exempted from taxes levied on their remunerations in which the place of effective management of the enterprise is situatedthat other Contracting State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 1516, 17, 18, 18 and 19 and 20 of this Agreement, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment em- ployment shall be taxable only in that 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 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 within any twelve twelve-month period commencing or ending in the fiscal calendar year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment 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 the Contracting State in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 18 and 20 of this Agreement20, 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 any twelve month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) the remuneration is not borne by a permanent establishment which the employer has in the other State. (3) . Notwithstanding the preceding provisions of this Article, remuneration derived derived, in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the by an enterprise of a Contracting State shall be taxable only in which the place of effective management of the enterprise is situatedthat State.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 1516, 17, 18, 19 18 and 20 of this Agreement19, salaries, wages and other similar remuneration derived by a resident of a Contracting State territory in respect of an employment shall be taxable only in that State territory unless the employment is exercised in the other Contracting Stateterritory. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Stateterritory. (2) . Notwithstanding the provisions of paragraph (1) of this Article, salaries, wages and other similar remuneration derived by a resident of a Contracting State territory in respect of an employment exercised in the other Contracting State territory shall be taxable only in the first-first- mentioned State territory if: (a) the recipient is present in the other State territory for a period or periods not exceeding in the aggregate 183 days in any twelve twelve-month period commencing or ending in the fiscal year concerned; , and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; territory, and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Stateterritory. (3) . Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, may be taxed in the Contracting State in territory of which the place of effective management of the enterprise is situateda resident.

INCOME FROM EMPLOYMENT. (1) . Subject to the provisions of Articles 15, 17, 18, 19 and 20 of this Agreement20, 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) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned; , and (b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and (c) c. the remuneration is not borne by a permanent establishment 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 in relation only to a ship or aircraft operated in international traffic may be taxed in the by a resident of a Contracting State shall be taxable only in which that State. This paragraph shall not apply if the place of effective management employee is a resident or a national of the enterprise is situatedother Contracting State.

INCOME FROM EMPLOYMENT. (1) Subject to the provisions of Articles 15, 17, 18, 18 and 19 and 20 of this AgreementConvention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 any twelve month period commencing or ending in the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and (c) the remuneration is not borne by a permanent establishment 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 the Contracting State in which the place of effective management of the enterprise is situatedthat State.