Common use of Personal Services Clause in Contracts

Personal Services. 1. Subject to the provisions of Articles 16, 18, 19 and 20, salaries, wages and other similar remuneration in respect of an employment as well as income in respect of professional services or other independent activities of a similar character, derived by a resident of one of the States, shall be taxable only in that State, unless the employment, services or activities are exercised or performed in the other State. If the employment, services or activities are so exercised or performed, such remuneration or income as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration or income, derived by a resident of one of the States in respect of an employment, services or activities exercised or performed in the other State shall be taxable only in the first-mentioned State if - (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and (b) the remuneration or income is paid by, or on behalf of, a person who is not a resident of the other State; and (c) the remuneration or income is not borne by a permanent establishment which that person has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of one of the States in respect of an employment exercised aboard a ship or aircraft in international traffic shall be taxable only in that State.

Personal Services. 1. Subject to the provisions of Articles 1615, 1817, 19 18 and 2019, salaries, wages and other similar remuneration in respect of an employment as well as income in respect of professional services or other independent activities of a similar character, derived by a resident of one of the Statesa Contracting State, shall be taxable only in that State, State unless the employment, services or activities are exercised or performed in the other Contracting State. If the employment, services or activities are so exercised or performed, such remuneration or income as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration or income, income derived by a resident of one of the States a Contracting State in respect of an employment, services or activities exercised or performed in the other Contracting State shall be taxable only in the first-mentioned State if -if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; , and (b) the remuneration or income is paid by, or on behalf of, a person who is not a resident of the other first-mentioned State; , and (c) the remuneration or income is not borne by a permanent establishment which that person has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of one of the States in respect of an employment exercised aboard a ship or aircraft in international traffic shall be taxable only in that State.

Personal Services. 1. Subject to the provisions of Articles 1615, 1817, 19 18 and 2019, salaries, wages and other similar remuneration in respect of an employment as well as income in respect of professional services or other independent activities of a similar character, derived by a resident of one of the Statesa Contracting State, shall be taxable only in that State, State unless the employment, services or activities are exercised or performed in the other Contracting State. If the employment, services or activities are so exercised or performed, such remuneration or income as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration or income, income derived by a resident of one of the States a Contracting State in respect of an employment, services or activities exercised or performed in the other Contracting State shall be taxable only in the first-mentioned State if -if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; , and (b) the remuneration or income is paid by, or on behalf of, a person who is not a resident of the other first-mentioned State; , and (c) the remuneration or income is not borne by a permanent establishment which that person has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of one of the States a Contracting State in respect of an employment exercised aboard a ship or aircraft in international traffic shall be taxable only in that State.

Personal Services. 1. Subject to the provisions of Articles 1615, 17, 18, 19 and 20, salaries, wages and other similar remuneration in respect of an employment as well as income in respect of professional services or other independent activities of a similar an independent character, derived by a an individual resident of one of the Statesa Contracting State, shall be taxable only in that State, unless the employment, services or activities are exercised or performed in the other Contracting State. If the employment, services or activities are so exercised or performed, such remuneration or income as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration or income, income derived by a resident of one of the States a Contracting State in respect of an employment, services or activities exercised or performed in the other Contracting State shall be taxable only in the first-mentioned State if -if: (a) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; fiscal year, and (b) b. the remuneration or income is paid by, or on behalf of, a person who is not a resident of the other State; , and (c) c. the remuneration or income is not borne by a permanent establishment which that person has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of one of the States in respect of an employment exercised aboard a ship or aircraft operated in international traffic shall be taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.

Personal Services. 1. Subject to the provisions of Articles 16, 18, 19 and 20, salaries, wages and other similar remuneration in respect of an employment as well as income in respect of professional services or other independent activities of a similar character, derived by a resident of one of the States, shall be taxable only in that State, unless the employment, services or activities are exercised or performed in the other State. If the employment, services or activities are so exercised or performed, such remuneration or income as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration or income, derived by a resident of one of the States in respect of an employment, services or activities exercised or performed in the other State shall be taxable only in the first-mentioned State if -if: (a) the The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned; and (b) the The remuneration or income is paid by, or on behalf of, a person who is not a resident of the other State; and (c) the The remuneration or income is not borne by a permanent establishment which that person has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of one of the States in respect of an employment exercised aboard a ship or aircraft in international traffic shall be taxable only in that State.