Common use of Income of Individuals Clause in Contracts

Income of Individuals. 1. Notwithstanding the provisions of Article 10 of this Convention, wages, salaries and other similar remuneration which an individual resident in a Contracting State receives for performing services in the other Contracting State shall be taxable in that other Contracting State if: (a) such person is present in that other State for a period or periods exceeding an aggregate of 183 days in a calendar year; (b) the wages, salaries and remuneration are paid by or on behalf of an employer who is a resident of that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 of this Article, remuneration which a resident of a Contracting State receives in consideration for services performed in the other Contracting State shall not be liable to taxation in that other State if it is subjected to taxation in the first-mentioned State and on the condition that it concerns the following remuneration: (a) remuneration in respect of work directly connected with a construction or assembly project as referred to in Article 6 of this Convention, for the period of time indicated in that Article; (b) remuneration which an individual who is present in a Contracting State at the invitation of a government agency or other government entity, or an educational or scientific research institution of that State for the purposes of teaching, scientific research, or participating in technical, scientific or professional conferences or for carrying out inter-governmental programmes of cooperation, receives for such above-mentioned activities during a period not exceeding two years, and provided such activity does not mainly serve the personal interests of that individual; (c) study grants paid to individuals, who are present in the other Contracting State for the purposes of completing their study or professional training, as well as cash payments received by these persons from sources outside that other State for the purpose of their maintenance, education or professional training during the period of time necessary to complete their study or professional training; (d) remuneration paid to individuals stationed in the other Contracting State as press, radio or television reporters or representatives, from sources outside that other State for two years from their arrival in that other State; (e) remuneration paid to personnel of permanent representations of tourist institutions of a Contracting State situated in the other Contracting State for non-profit activities on the condition that they are nationals of the first-mentioned Contracting State; (f) remuneration derived from artistic and athletic performances or other public entertainments within the scope of an exchange under cultural agreements concluded between the Contracting States; (g) remuneration derived by residents of a Contracting State, sent as technical specialists to the other Contracting State, during a year from the date of arrival in that other State. 3. For the purposes of paragraph 2 of this Article, individuals may be subject to taxation only on income derived after the expiration of the tax relief provisions mentioned in that paragraph.

Income of Individuals. 1. Notwithstanding the provisions of Article 10 of this Convention, wages, salaries Xxxxx and other similar remuneration which remunerations of an individual resident in a Contracting State receives received for performing services in activity on the territory of the other Contracting State and not exempt from taxation in accordance with paragraph 2 of this Article and other articles of this Convention, shall not be taxable liable to taxation in that other Contracting State ifState: (a) such a. if the above-mentioned person is present in that other State for therein during a period or periods not exceeding an aggregate of 183 days in a calendar yearyear and, in the case of technical specialists -- 365 days in two consecutive calendar years; (b) the wages, salaries b. If these wages and remuneration remunerations are paid by by, or on behalf of of, an employer who is not a resident of that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 1, the following categories of this Article, remuneration which income of individuals resident in a resident of a Contracting State receives in consideration for services performed in the other Contracting State shall not be liable to taxation in that the other State if it is subjected to taxation Contracting State: a. income in the first-mentioned State and on the condition that it concerns the following remuneration: (a) remuneration form of salary or wages in respect of work directly done in the other Contracting State connected with a construction or assembly project as referred to wherefrom the profits are exempt from taxation in that other State in accordance with paragraph 4, of Article 6 4 of this Convention, for the period of time indicated in that Article; (b) remuneration which an individual who is b. income of a person present in a the other Contracting State at the invitation of a government agency or other government entityinstitution, or an educational or scientific research institution establishment of that Contracting State for the purposes of teachingto teach, conduct scientific researchresearch or participate in scientific, or participating in technical, scientific technical or professional conferences or for the purpose of carrying out inter-governmental the programmes of cooperation, receives for such if the income is derived from the activities indicated above-mentioned . The provisions of this paragraph shall not apply in cases where the performance of activities during a period not exceeding two years, and provided such activity does not indicated above mainly serve serves the personal interests of that individuala resident of the first-mentioned Contracting State; (c) study grants c. Grants paid to individualspupils, students, postgraduate students or trainees who are present in the other Contracting State for the purposes purpose of completing their study studying or professional trainingacquiring experience in a particular field, as well as and also cash payments received by these persons from sources outside that other Contracting State for the purpose of their maintenancemaintaining of subsistence level, education or professional training during the in a particular field. Privileges provided for in this paragraph shall be granted for a period of time necessary to complete their study or professional trainingachieve the object of stay; (d) x. remuneration paid to individuals persons stationed in the other Contracting State as press, radio or television reporters or representativescorrespondents, from sources outside that other State for two years from their arrival in that other State; (e) remuneration e. salary or wages paid to personnel of transport vehicles used for international traffic by one of the Contracting States or by a person resident therein, and also the salary or wages of the personnel of a permanent representations establishment of a person operating these transport vehicles if the salary or wages of such personnel are received for work directly related to the performance of such traffic operations and if they are paid to persons other than residents of the State where the permanent establishment is situated; f. salary or wages paid to personnel of a permanent establishment of tourist institutions organizations if these remunerations are paid to persons other than residents of the State where the permanent establishment is situated; g. income received from tour performances and other public performances; h. sums of prizes, premiums and remunerations paid to participants and winners of sportive and other performances and competitions; i. Sums paid as compensation for damage or injury caused. 3. An individual who is a resident of a Contracting State situated in shall not be deemed to be a resident of the other Contracting State for non-profit by mere reason that he performs any of the activities enumerated in paragraph 2 on the condition that they are nationals territory of the first-mentioned Contracting State; (f) remuneration derived from artistic and athletic performances or other public entertainments within the scope of an exchange under cultural agreements concluded between the Contracting States; (g) remuneration derived by residents of a Contracting State, sent as technical specialists to the other Contracting State, during a year from the date of arrival in that other State. 34. For In the purposes application of paragraph 2 the provisions of this Articleparagraphs 1 and 2, taxes shall be imposed on the basis of income received by individuals may be subject to taxation only on income derived after the date of expiration of the tax relief provisions maximum favourable terms mentioned in that paragraphparagraphs 1 and 2.

Income of Individuals. 1. Notwithstanding the provisions of Article 10 of this Convention, wages, salaries Wages and other similar remuneration which remunerations of an individual resident in a Contracting State receives received for performing services in activity on the territory of the other Contracting State and not exempt from taxation in accordance with paragraph 2 of this Article and other articles of this Convention, shall not be taxable liable to taxation in that other Contracting State ifState: (a) such a. if the above-mentioned person is present in that other State for therein during a period or periods not exceeding an aggregate of 183 days in a calendar yearyear and, in the case of technical specialists -- 365 days in two consecutive calendar years; (b) the wages, salaries b. If these wages and remuneration remunerations are paid by by, or on behalf of of, an employer who is not a resident of that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 1, the following categories of this Article, remuneration which income of individuals resident in a resident of a Contracting State receives in consideration for services performed in the other Contracting State shall not be liable to taxation in that the other State if it is subjected to taxation Contracting State: a. income in the first-mentioned State and on the condition that it concerns the following remuneration: (a) remuneration form of salary or wages in respect of work directly done in the other Contracting State connected with a construction or assembly project as referred to wherefrom the profits are exempt from taxation in that other State in accordance with paragraph 4, of Article 6 4 of this Convention, for the period of time indicated in that Article; (b) remuneration which an individual who is b. income of a person present in a the other Contracting State at the invitation of a government agency or other government entityinstitution, or an educational or scientific research institution establishment of that Contracting State for the purposes of teachingto teach, conduct scientific researchresearch or participate in scientific, or participating in technical, scientific technical or professional conferences or for the purpose of carrying out inter-governmental the programmes of cooperation, receives for such if the income is derived from the activities indicated above-mentioned . The provisions of this paragraph shall not apply in cases where the performance of activities during a period not exceeding two years, and provided such activity does not indicated above mainly serve serves the personal interests of that individuala resident of the first-mentioned Contracting State; (c) study grants c. Grants paid to individualspupils, students, postgraduate students or trainees who are present in the other Contracting State for the purposes purpose of completing their study studying or professional trainingacquiring experience in a particular field, as well as and also cash payments received by these persons from sources outside that other Contracting State for the purpose of their maintenancemaintaining of subsistence level, education or professional training during the in a particular field. Privileges provided for in this paragraph shall be granted for a period of time necessary to complete their study or professional trainingachieve the object of stay; (d) d. remuneration paid to individuals persons stationed in the other Contracting State as press, radio or television reporters or representativescorrespondents, from sources outside that other State for two years from their arrival in that other State; (e) remuneration e. salary or wages paid to personnel of transport vehicles used for international traffic by one of the Contracting States or by a person resident therein, and also the salary or wages of the personnel of a permanent representations establishment of a person operating these transport vehicles if the salary or wages of such personnel are received for work directly related to the performance of such traffic operations and if they are paid to persons other than residents of the State where the permanent establishment is situated; f. salary or wages paid to personnel of a permanent establishment of tourist institutions of a Contracting State situated in the organizations if these remunerations are paid to persons other Contracting State for non-profit activities on the condition that they are nationals than residents of the first-mentioned Contracting StateState where the permanent establishment is situated; (f) remuneration derived g. income received from artistic tour performances and athletic performances or other public entertainments within the scope of an exchange under cultural agreements concluded between the Contracting Statesperformances; (g) remuneration derived by residents of a Contracting State, sent as technical specialists to the other Contracting State, during a year from the date of arrival in that other State. 3. For the purposes of paragraph 2 of this Article, individuals may be subject to taxation only on income derived after the expiration of the tax relief provisions mentioned in that paragraph.

Income of Individuals. 1. Notwithstanding the provisions of Article 10 of this Convention, wages, salaries Xxxxx and other similar remuneration which remunerations of an individual resident in a Contracting State receives received for performing services in activity on the territory of the other Contracting State and not exempt from taxation in accordance with paragraph 2 of this Article and other articles of this Convention, shall not be taxable liable to taxation in that other Contracting State ifState: (a) such a. if the above-mentioned person is present in that other State for therein during a period or periods not exceeding an aggregate of 183 days in a calendar yearyear and, in the case of technical specialists -- 365 days in two consecutive calendar years; (b) the wages, salaries b. If these wages and remuneration remunerations are paid by by, or on behalf of of, an employer who is not a resident of that other Contracting State. 2. Notwithstanding the provisions of paragraph 1 1, the following categories of this Article, remuneration which income of individuals resident in a resident of a Contracting State receives in consideration for services performed in the other Contracting State shall not be liable to taxation in that the other State if it is subjected to taxation Contracting State: a. income in the first-mentioned State and on the condition that it concerns the following remuneration: (a) remuneration form of salary or wages in respect of work directly done in the other Contracting State connected with a construction or assembly project as referred to wherefrom the profits are exempt from taxation in that other State in accordance with paragraph 4, of Article 6 4 of this Convention, for the period of time indicated in that Article; (b) remuneration which an individual who is b. income of a person present in a the other Contracting State at the invitation of a government agency or other government entityinstitution, or an educational or scientific research institution establishment of that Contracting State for the purposes of teachingto teach, conduct scientific researchresearch or participate in scientific, or participating in technical, scientific technical or professional conferences or for the purpose of carrying out inter-governmental the programmes of cooperation, receives for such if the income is derived from the activities indicated above-mentioned . The provisions of this paragraph shall not apply in cases where the performance of activities during a period not exceeding two years, and provided such activity does not indicated above mainly serve serves the personal interests of that individuala resident of the first-mentioned Contracting State; (c) study grants c. Grants paid to individualspupils, students, postgraduate students or trainees who are present in the other Contracting State for the purposes purpose of completing their study studying or professional trainingacquiring experience in a particular field, as well as and also cash payments received by these persons from sources outside that other Contracting State for the purpose of their maintenancemaintaining of subsistence level, education or professional training during the in a particular field. Privileges provided for in this paragraph shall be granted for a period of time necessary to complete their study or professional trainingachieve the object of stay; (d) x. remuneration paid to individuals persons stationed in the other Contracting State as press, radio or television reporters or representativescorrespondents, from sources outside that other State for two years from their arrival in that other State; (e) remuneration e. salary or wages paid to personnel of transport vehicles used for international traffic by one of the Contracting States or by a person resident therein, and also the salary or wages of the personnel of a permanent representations establishment of a person operating these transport vehicles if the salary or wages of such personnel are received for work directly related to the performance of such traffic operations and if they are paid to persons other than residents of the State where the permanent establishment is situated; f. salary or wages paid to personnel of a permanent establishment of tourist institutions of a Contracting State situated in the organizations if these remunerations are paid to persons other Contracting State for non-profit activities on the condition that they are nationals than residents of the first-mentioned Contracting StateState where the permanent establishment is situated; (f) remuneration derived g. income received from artistic tour performances and athletic performances or other public entertainments within the scope of an exchange under cultural agreements concluded between the Contracting Statesperformances; (g) remuneration derived by residents of a Contracting State, sent as technical specialists to the other Contracting State, during a year from the date of arrival in that other State. 3. For the purposes of paragraph 2 of this Article, individuals may be subject to taxation only on income derived after the expiration of the tax relief provisions mentioned in that paragraph.