ARTICLE 15
Dependent Personal Services
1. Subject to the provisions of Articles 16 (Directors’ Fees), 18 (Pensions), and 19 (Public
Remuneration), 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 any 12-month period commencing or ending in the taxable
period concerned;
(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 by a
resident of a Contracting State in respect of an employment exercised as a member of the regular
complement of a ship or aircraft operated in international traffic shall be taxable only in that
State.