Common use of DEPENDENT PERSONAL SERVICES Clause in Contracts

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, 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 de- rived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding in the aggregate 183 days in any twelve month period commenc- ing or ending in the fiscal year concerned, and b) the remuneration is paid by, or on behalf of, an employer who is not a res- ident 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective manage- ment of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 2121 of this Convention, 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 de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned State if: (a) the The recipient is present in the other State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing commencing or ending in the fiscal year concerned, ; and (b) the The remuneration is paid by, or on behalf of, an employer who is not a res- ident resident of the other State, ; and (c) the 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State in which the place of effective manage- ment profits from the operation of the enterprise is situatedship or aircraft are taxable according to the provisions of Article 8.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 2121 of this Convention, 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 de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned State if: (a) the The recipient is present in the other State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing commencing or ending in the fiscal year concerned, ; and (b) the The remuneration is paid by, or on behalf of, an employer who is not a res- ident resident of the other State, ; and (c) the 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State in which the place of effective manage- ment management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, 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 de- rived derived therefrom may be taxed in that other State.. Articles 15, 16 and 17 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned State if: (a) the The recipient is present in the other State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing com- mencing or ending in the fiscal year concerned, ; and (b) the The remuneration is paid by, or on behalf of, an employer who is not a res- ident resident of the other State, ; and (c) the 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 remunera- tion derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, or aboard a boat engaged in inland water- ways transport, may be taxed in the Contracting State in which the place of effective manage- ment management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 2121 of this Agreement, 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 de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding exceeding in the aggregate 183 one hundred and eighty three (183) days in any twelve month period commenc- ing 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 res- ident 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic may traffic, shall be taxed taxable only in the Contracting State in of which the place of effective manage- ment of enterprise operating the enterprise ship or aircraft is situateda resident.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2121 of this Convention, 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 de- rived derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding exceeding in the aggregate 183 days in any twelve 12-month period commenc- ing 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 res- ident 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 Contracting 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 the Contracting State in which the place of effective manage- ment of the enterprise is situatedthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 2121 of this Convention, 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 de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned State if: (a) the The recipient is present in the other State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing commencing or ending in the fiscal year concerned, ; and (b) the The remuneration is paid by, or on behalf of, an employer who is not a res- ident resident of the other State, ; and (c) the 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 in respect of an employment exercised aboard a ship ship, an aircraft or aircraft a road vehicle operated in international traffic traffic, may be taxed in the Contracting State in which the place of effective manage- ment management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, 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 de- rived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding exceed- ing in the aggregate 183 days in any twelve month period commenc- ing 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 res- ident resi- dent 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective manage- ment of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting Con- tracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting Con- tracting State. If the employment is so exercised, such remuneration as is de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment employ- ment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned State if: (a) the The recipient is present in the other State for a period or periods peri- ods not ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing commencing or ending in the fiscal year concerned, ; and (b) the The remuneration is paid by, or on behalf of, an employer who is not a res- ident resident of the other State, ; and (c) the 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 Articlearticle, remuneration re- muneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, or aboard a boat en- gaged in inland waterways transport, may be taxed in the Contracting ARTICLES 15, 16 AND 17 State in which the place of effective manage- ment management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 18 and 2119 of this Agreement, 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 de- rived derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned State if: a) the recipient is present in the other Contracting State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing 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 res- ident resident of the other Contracting State, and c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting 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 traffic, may be taxed in the Contracting State in which the place of effective manage- ment management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by an individual who is 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 de- rived therefrom derived from that exercise may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by an individual who is a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding exceeding in the aggregate 183 days in any twelve 12 month period commenc- ing commencing or ending in the fiscal year concerned, of income of that other State; and (b) the remuneration is paid by, or on behalf of, an employer who is not a res- ident resident of the that other State, ; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the that 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 may be taxed in the Contracting State in of which the place of effective manage- ment of the enterprise is situateda resident.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment em- ployment 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 de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent of a Contracting State in respect of an employment exercised in the other Contract- ing Con- tracting State shall be taxable only in the first-mentioned State if: a) the The recipient is present in the other State for a period or periods not ex- ceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing or ending in the fiscal year concerned, ; and b) the The remuneration is paid by, or on behalf of, an employer who is not a res- ident of the other State, ; and c) the The remuneration is not borne by a permanent establishment or a fixed base base, 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 the Contracting State in which the place of effective manage- ment of the enterprise is situatedthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment em- ployment 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 de- rived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding in the aggregate 183 days in any twelve month period commenc- ing or ending in the fiscal year concerned, and b) the remuneration is paid by, or on behalf of, an employer who is not a res- ident 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 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 that Contracting State in which the place of effective manage- ment of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1817, 19, 20 20, 21 and 2122, 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 de- rived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding in the aggregate 183 days in any twelve month period commenc- ing or ending in the fiscal year concerned, and b) the remuneration is paid by, or on behalf of, an employer who is not a res- ident 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State in which the place of effective manage- ment of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18, 19, 19 and 20 and 21of this Agreement, 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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is de- rived derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned Contracting State if: a) the recipient is present in the other Contracting State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing 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 res- ident resident of the other Contracting State, and c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting 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 traffic, may be taxed in the Contracting State in which the place of effective manage- ment of enterprise operating the enterprise ship or aircraft is situateda resident.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar simi- lar 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 Con- tracting State. If the employment is so exercised, such remuneration as is de- rived therefrom derived there- from may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent of a Contracting State in respect of an employment exercised in the other Contract- ing State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve 12-month period commenc- ing 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 res- ident resident of the other Contracting State, ; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting 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 a resident of a Contracting State may be taxed in the Contracting State in which the place of effective manage- ment of the enterprise is situatedthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2121 of this Agreement, 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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is de- rived derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned Contracting State if: a) a. the recipient is present in the other Contracting State for a period or periods not ex- ceeding exceeding in the aggregate 183 182 days in any twelve 12-month period commenc- ing commencing or ending in the fiscal year concerned, ; and b) b. the remuneration is paid by, or on behalf of, an employer who is not a res- ident resident of the other Contracting State, ; and c) c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting 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 may be taxed in the Contracting State in which the place of effective manage- ment management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 17, 18, 19, 20 and 2121 of this Agreement, 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 de- rived derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing 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 res- ident 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic may shall be taxed taxable only in the Contracting a State in which the place of effective manage- ment management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18, 19, 20 and 2120, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be s hall b e taxable only in that Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is de- rived therefrom derived there from may be taxed in that other Contracting State. (2. ) Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned Contracting State if: a) the recipient is present in the other Contracting State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve month period commenc- ing 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 res- ident resident of the other Contracting State, and c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting 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 traffic, may be taxed in the Contracting State in which the place of effective manage- ment of enterprise operating the enterprise ship or aircraft is situateda resident.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1616 (Directors’ fees), 18, 19, 20 18 (Pensions) and 2119 (Government service), 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 de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-first mentioned State if: a) the recipient is present in the other State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve month period commenc- ing commencing or ending in the fiscal year concerned, and b) the remuneration is paid by, or on behalf of, a person being an employer who is not a res- ident resident of the other State, and c) the remuneration is not borne by a permanent establishment or a fixed base which that the person being an 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 the Contracting State in which the place of effective manage- ment of the enterprise is situatedby that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 2121 of this Convention, 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 de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding exceeding in the aggregate 183 days in any twelve month period commenc- ing 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 res- ident 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, may be taxed in the Contracting State in of which the place of effective manage- ment of enterprise operating the enterprise ship or aircraft is situateda resident.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 17, 18, 19, 20 and 2121 of this Agreement, 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 de- rived derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing Contracting State shall be taxable only in the first-first- mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing 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 res- ident 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic may shall be taxed taxable only in the Contracting a State in which the place of effective manage- ment management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, 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 de- rived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding in the aggregate 183 days in any twelve month period commenc- ing or ending in the fiscal year concerned, and b) the remuneration is paid by, or on behalf of, an employer who is not a res- ident 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 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 that Contracting State in which the place of effective manage- ment of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, 21 of this Convention 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 de- rived derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 11of this Article , remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing 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 res- ident 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic may by an enterprise of a Contracting State shall be taxed taxable only in the Contracting State in which the place of effective manage- ment management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, 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 de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding exceeding in the aggregate 183 days in any twelve month period commenc- ing 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 res- ident resident of the other StateState and whose activity does not consist of hiring out of labour, 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 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. Where a resident of a Contracting States derives remuneration in respect of an employment exercised aboard an aircraft operated in international traffic by the Scandinavian Airlines System (SAS) consortium, such remuneration shall be taxable only in that Contracting State in which the place of effective manage- ment of the enterprise is situatedState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 2121 of this Agreement, 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 de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment exercised in the other Contract- ing 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 ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing commencing or ending in the fiscal taxable year concerned, ; and b) the remuneration is paid by, or on behalf of, an employer who is not a res- ident 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 in respect of an employment exercised aboard a ship ship, aircraft or aircraft road vehicle operated in international traffic traffic, may be taxed in the Contracting State in which the place of effective manage- ment management of the enterprise is situated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting Con- tracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting Con- tracting State. If the employment is so exercised, such remuneration as is de- rived derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi- dent resident of a Contracting State in respect of an employment employ- ment exercised in the other Contract- ing Contracting State shall be taxable only in the first-mentioned State if: (a) the The recipient is present in the other State for a period or periods peri- ods not ex- ceeding exceeding in the aggregate 183 days in any twelve twelve-month period commenc- ing commencing or ending in the fiscal year concerned, ; and (b) the The remuneration is paid by, or on behalf of, an employer who is not a res- ident resident of the other State, ; and (c) the 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 Articlearticle, remuneration re- muneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, or aboard a boat en- gaged in inland waterways transport, may be taxed in the Contracting Articles 15, 16 and 17 State in which the place of effective manage- ment management of the enterprise is situated.