ARTICLE 16
Dependent Personal Services
1. Subject to the provisions of Articles 17 (Directors'
Fees), 18 (Income Earned by Entertainers and Athletes), 19
(Remuneration and Pensions in Respect of Government Service), 20
(Private Pensions, Annuities, Alimony, and Child Support), 21
(Payments Received by Students and Apprentices) and 22 (Payments
Received by Professors, Teachers and Research Scholars),
salaries, wages, and other similar remuneration derived by a
resident of a Contracting state in respect of an employment shall
be taxable only in that state unless the employment is exercised
in the other Contracting state. If the employment is so
exercised, such remuneration as is derived therefrom may be taxed
in that other state.
2. Notwithstanding the provisions of paragraph 1,
remuneration derived by a resident of a Contracting state in
respect of an employment exercised in the other Contracting state
shall be taxable only in the first-mentioned state if:
a) the recipient is present in the other state for a
period or periods not exceeding in the aggregate 183 days in
the relevant taxable year;
b) the remuneration is paid by, or on behalf of, an
employer who is not a resident of the other state; and
c) the remuneration is not borne by a permanent
establishment or a fixed base or a trade or business which
the employer has in the other state.
3. Notwithstanding the preceding provisions of this Article,
remuneration derived in respect of an employment exercised aboard
a ship or aircraft operated in international traffic by an
enterprise of a Contracting state may be taxed in that state.