(1) Subject to the provisions of Articles 15‚ 17‚ 18 and 19‚ 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 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.
(4) Notwithstanding the preceding provisions‚ 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 State of which that enterprise is a
resident.