DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 15, 17 and 18, 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 or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 6 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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 tax year concerned; , and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise a resident of a Contracting State, may be taxed in that State.
4. Where a resident of a Contracting State derives remuneration in respect of an employment exercised aboard an aircraft operated in international traffic by an air transport consortium formed by companies from different countries including a company that is a resident of that State, such remuneration shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 6 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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-twelve month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless State. However, if the remuneration is derived by a resident of the other Contracting State, it may also be taxed in that other State.
Appears in 5 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819 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 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-twelve month period commencing or ending in the fiscal year concerned; , and
(b) the remuneration is paid by by, or on behalf of 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 paragraphs 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 shall be taxable only in that State unless State. However, if the remuneration is derived by a resident of the other Contracting State, it may also be taxed in that other State.
Appears in 5 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 of twelve months commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other first-mentioned Contracting 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 shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of effective management of the other Contracting Stateenterprise is situated.
Appears in 5 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of. an employer who is not a 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 an enterprise a resident of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 5 contracts
Sources: Double Taxation Agreement, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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 twelve12-month period commencing or ending in the fiscal year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless State. However, if the remuneration is derived by a resident of the other Contracting State, it may also be taxed in that other State.
Appears in 5 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 1516, 17 18, 19, and 1820, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-twelve month period commencing or ending in the fiscal year concerned; , and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration enterprise operating the ship or aircraft is derived by a resident of the other Contracting Stateresident.
Appears in 5 contracts
Sources: Convention With Respect to Taxes on Income and on Capital, Convention on Taxes, Convention With Respect to Taxes on Income and on Capital
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; , and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 an enterprise of a Contracting State shall State, may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 5 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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-twelve month period commencing or ending in the fiscal year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 4 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 1516, 17 18 and 1819, 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-twelve month period commencing or ending in the fiscal year concerned; , and
(b) the remuneration is paid by by, or on behalf of 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 paid by an enterprise of a Contracting State in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall traffic, may be taxable taxed only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 4 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 17, 18, 19 and 1820, 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 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 by, or on behalf of 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 place which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, the remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft operated operating in international traffic by an enterprise of traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident place of effective management of the other Contracting Stateenterprise is situated.
Appears in 4 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1821 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 derived therefrom may be taxed in that other Contracting State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 182 days in any twelve12-month period commencing or ending in the fiscal year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 an enterprise of a may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident place of effective management of the other Contracting Stateenterprise is situated.
Appears in 4 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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 11 above, 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 calendar year concerned; , and
(b) the remuneration is paid by by, or on behalf of 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, and
(d) the remuneration is subject to tax in the first-mentioned 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 shall be taxable only in that the Contracting State unless in which the place of effective management of the enterprise which operates the ship or aircraft is situated. However, if the remuneration is derived by a resident of the other Contracting State, it may also be taxed in that other State.
Appears in 4 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 17, 18, 19, 20 and 1821, salaries, wages and other similar simliar 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that State unless of which the remuneration enterprise is derived by a resident of the other Contracting Stateresident.
Appears in 4 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 and 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 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 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 calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 3 contracts
Sources: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 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 exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 an enterprise of a Contracting State traffic, shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of head office (place of effective management) of the other Contracting Stateenterprise is situated.
Appears in 3 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1paragraph1, 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-twelve month period commencing or ending in the fiscal year concerned; , and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, shall be taxable only in that the Contracting State unless in which the remuneration enterprise operating the ship or aircraft is derived by a resident of the other Contracting Stateresident.
Appears in 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting State.
2. Notwithstanding the provisions provisiona 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 firstmentioned State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 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 in international traffic, shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of head affice (i.e. effective management) of the other Contracting Stateenterprise is situated.
Appears in 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in within any twelve-month period commencing or ending in the fiscal year concernedof 12 months; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise which is a resident of a Contracting State in international traffic, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve12-month period commencing or ending in the fiscal year concernedperiod; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 of this Articlearticle, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise which is a resident of a Contracting State in international traffic, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal taxable year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise which is a resident of a Contracting State in international traffic shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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 calendar year concerned; and
(b) the remuneration is paid by services are rendered for or on behalf of an employer of, a person who is not a resident of the other first-mentioned State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer person 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 shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of effective management of the other Contracting Stateenterprise is situated.
Appears in 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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 concernedperiod; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship ship, aircraft or aircraft road or railway vehicle operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless State. However, if the remuneration is derived by a resident of the other Contracting State, it may also be taxed in that other State.
Appears in 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 15, 17 16,18,19,20 and 18, salaries, 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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other Contracting 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-first mentioned State if:
(a) the recipient is present in the other Contracting 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 by, or on behalf of of, an employer who is not a 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 an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that State unless of which the remuneration enterprise is derived by a resident of the other Contracting Stateresident.
Appears in 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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-twelve month period commencing or ending in the fiscal year concerned; , and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident place of effective management of the other Contracting Stateenterprise is situated.
Appears in 3 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 15, 17 16,18,19,20 and 18, salaries, wages 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, remuneration 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-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 concerned365 day period; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft, other than a ship or aircraft operated solely between places in international traffic by an enterprise of a one Contracting State, may be taxable in the Contracting State of which the employer is a resident. Where the employment is exercised aboard a ship or aircraft operated solely between places in one Contracting State paragraphs 1 and 2 shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting Stateapply.
Appears in 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 15l6, 17 l8, l9, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 that other Contracting State for a period or periods not exceeding in the aggregate 183 days in within any twelve-twelve month period commencing or ending in the fiscal year concernedperiod; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 3 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State if:
(a) the recipient resident is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820, 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 calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other first-mentioned 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 shall be taxable only in that State State, unless the remuneration is derived by a resident of the other Contracting State.
Appears in 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the that other Contracting State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the that other Contracting State.
3. Notwithstanding the preceding provisions of this Articleparagraphs 1 and 2, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international internatonal traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident place of head office or of effective management of the other Contracting Stateenterprise is situated.
Appears in 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other Contracting State; and
(c) the remuneration is not borne by a resident or 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 3 contracts
Sources: Double Taxation Avoidance Agreement, Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions provision of Articles 1516, 17 and 17, 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 exercisedexercised in the other Contracting State, 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 calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard abroad a ship or aircraft operated in international traffic by an of the enterprise of a Contracting State as specified in paragraph 1 of Article 8, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 1516, 17 17, 18, 19 and 1820 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 derived therefrom may be taxed in that other State.
(2. ) Notwithstanding the provisions of paragraph (1) of this Article, 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 ifif :
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in within any twelve-month continuous period commencing or ending in the fiscal year concernedof twelve months; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that State unless of which the remuneration is derived by a resident person deriving the profits from the operation of the other Contracting Stateship or aircraft is a resident.
Appears in 2 contracts
Sources: Agreement Between the Government of the Republic of Indonesia and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income and Capital Gains, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 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 shall in international traffic, may be taxable only taxed in that the Contracting State unless in which the remuneration is derived by a resident place of head office (i.e. effective management) of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1821, 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) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve-twelve month period commencing or ending in the fiscal year concerned; , and
(b) b. the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other State; , and
(c) 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 shall be taxable only in that State unless the remuneration is derived by State.
4. Where a resident of Denmark derives remuneration in respect of an employment exercised aboard an aircraft operated in international traffic by the other Contracting StateScandinavian Airlines System (SAS) consortium, such remuneration shall be taxable only in Denmark.
Appears in 2 contracts
Sources: Double Taxation Agreement, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident place of effective management (i. e. head office) of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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) a. the recipient is present in the other State for a period or periods period not exceeding in the aggregate 183 days in any twelve-twelve month period commencing or ending in the fiscal year concerned; , and
(b) b. the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other State; , and
(c) 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 State, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 an enterprise of a Contracting State traffic, shall be taxable only in that the Contracting State unless in which the remuneration enterprise is derived by a resident of the other Contracting Stateresident.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 ifif :
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-12- month period commencing or ending in the fiscal year concernedperiod; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other State; andis
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.a
3. Notwithstanding the preceding provisions of paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise which is a *resident of a Contracting State in international traffic, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1517, 17 19 and 1820, 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 derived therefrom 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 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 that other State for a period or periods not exceeding in the aggregate 183 days in any twelve-12 month period commencing or ending in the fiscal year of income concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the that other State; and
(c) the remuneration is not borne by deductible in determining the taxable profits of 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 by an enterprise a resident of a Contracting State shall may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 l83 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 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 in international traffic, shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of head office of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State, if:
(a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the that other Contracting State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the that other Contracting State.
3. Notwithstanding the preceding provisions of this Articleparagraphs 1 and 2, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; : and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship ship, aircraft or aircraft land vehicle operated in international traffic by an enterprise of a Contracting State in international traffic, shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of head office of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820, 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 the. other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from 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 State, if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in within any twelve-twelve month period commencing or ending in the fiscal year concernedperiod; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 17, 18, 19, 20 and 1821, 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 Contracting 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-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 the relevant βprevious yearβ or ending in βtax yearβ concerned, as the fiscal year concerned; case may be, and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by an enterprise of the other Contracting State or 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 rmuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 commenting or ending in the fiscal year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of head office of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820, 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 calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 and 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 Contracting 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 Contracting State.
2. Notwithstanding the provisions of paragraph 1, remuneration remuncration 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period period, or periods not exceeding in the aggregate 183 days in any twelve-month period 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 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Agreement Between the Government of the Republic of Indonesia and the Government of the People's Republic of Bangladesh for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the People's Republic of Bangladesh for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 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 in international traffic, shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of head office (i. e. effective management) of the other Contracting Stateemploying enterprise is situated.
Appears in 2 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom from that exercise 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month consecutive period commencing or ending in the fiscal year concerned; andof 12 months;
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 Articleparagraphs (1) and (2), remuneration derived in respect of an employment exercised excercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State in international traffic, shall be taxable only in that the Contracting State unless of which the remuneration enterprise is derived by a resident of the other Contracting Stateresident.
Appears in 2 contracts
Sources: International Tax Agreements, International Tax Agreements
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 17, 18, 19 and 1820, 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 derived therefrom may be taxed in that other Contracting 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 firstmentioned Contracting State if:
(a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the that other Contracting State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the that other Contracting State.
3. Notwithstanding the preceding provisions of this Articleparagraphs 1 and 2, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise which is a resident of a Contracting State in international traffic, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820, 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-twelve month period commencing or ending in the fiscal year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable taxed only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820 of this Agreement, salaries, wages wages, gratuities 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 11 of this Article, 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-first- mentioned State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days six months in any twelve-month period commencing or ending in the fiscal year concernedcalendar year; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a resident or a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 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 in international traffic, shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of effective management of the other Contracting Statebusiness of the enterprise is situated.
Appears in 2 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 15, 17 16,18,19,20 and 18, 21 salaries, wages and other similar remuneration remuneration, other than a pension, 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 ifif :
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in within any twelve-month period commencing or ending in the fiscal year concerned; period, and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by State. Where a resident of Sweden derives remuneration in respect of an employment exercised aboard an aircraft operated in international traffic by the other Contracting Stateair transport consortium Scandinavian Articles System (SAS), such remuneration shall be taxable only in Sweden.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 17, 18 19, 20 and 18, salaries21,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-first- mentioned State ifif :
(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 by, or on behalf of of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by or paid on behalf of 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, by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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-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-twelve month period commencing or ending in the fiscal year concerned; , and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall State, may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 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 in international traffic, shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of head office of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 17, 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting 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 concernedof twelve months; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 an enterprise of a Contracting State, may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident place of head office (i. e. effective management) of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom there from may be taxed in that other Contracting 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 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 in international traffic, shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of head office of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting State.
2. Notwithstanding the provisions of paragraph 1l, 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 Articleparagraphs 1 and 2, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State in international traffic, shall be taxable only in that the Contracting State unless in which the remuneration is derived by a resident place of head office (effective management) of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1518, 17 19, 20, 21, 22 and 1823, 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 derived therefrom may be taxed in that other Contracting 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-first mentioned Contracting State if:
(a) a. the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the relevant fiscal year concerned; year, and
(b) b. the remuneration is paid by by, or on behalf of an employer who is not a 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 Articlearticle, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State. In case of aircraft, the term "enterprise of a Contracting State" shall have the same meaning as defined in paragraph 5 of Article 8 of this Agreement.
Appears in 2 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820, 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 The recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve-twelve month period commencing or ending in the fiscal calendar year concerned; , and
(b) the The remuneration is paid by by, or on behalf of of, an employer who is not a 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 by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 and 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 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 that other Contracting State for a period or periods not exceeding in the aggregate 183 days in within any twelve-twelve month period commencing or ending in the fiscal year concernedperiod; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the that other Contracting State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the that 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 shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Income Tax Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820, 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 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 within any twelve-month period commencing or ending in the fiscal year concernedperiod; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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.that
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 twelve12-month period commencing or ending in the fiscal year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless State. However, if the remuneration is derived by a resident of the other Contracting State, it may also be taxed in that other State.
Appears in 2 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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 by, or on behalf of 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 in respect of an employment exercised aboard a ship or an aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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 derived therefrom may be taxed in that other Contracting 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 Contracting State if:
(a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the that other Contracting State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the that other Contracting State.
3. Notwithstanding the preceding provisions of this Articleparagraphs 1 and 2, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State State, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820, 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 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 State, if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in within any twelve-twelve month period commencing or ending in the fiscal year concernedperiod; and
(b) the remuneration is paid by by, or on behalf of 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 provicions 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 shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income, Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of Mauritius for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 Contracting 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 concernedof 12 months; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft airpraft operated in international traffic by an enterprise of a Contracting State shall in international traffic, may be taxable only taxed in that the Contracting State unless in which the remuneration is derived by a resident place of head office or effective management of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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-twelve month period commencing or ending in the fiscal year concerned; , and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 2 contracts
Sources: Double Taxation Avoidance Agreement, Income Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820 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 derived therefrom may be taxed in that other State.
2. Notwithstanding 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 twelve months period commencing or ending in the fiscal year concerned; , and
(b) the The remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that the Contracting State unless in which the remuneration is derived by a resident place of effective management of the other Contracting Stateenterprise is situated.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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 ifif :
(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 calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident place of effective management of the other Contracting Stateenterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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-first- mentioned State if:
(a) the 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 The remuneration is paid by by, or on behalf of of, an employer who is not a 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 by an enterprise of traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident profits from the operation of the other Contracting Stateship or aircraft are taxable according to the provisions of Article 8.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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-twelve month period commencing or ending in the fiscal year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 15article 16, 17 and 18, salaries19, 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 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 by, or on behalf behall 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 in derived is respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State State, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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 concernedyear; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident place of effective management of the other Contracting Stateenterprise is situated in accordance with Article 8 of this Convention.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 1516, 17 17, 18, 19 and 1820 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 derived therefrom may be taxed in that other State.
(2. ) Notwithstanding the provisions of paragraph 11 of this Article, 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 within any twelve-month continuous period commencing or ending in the fiscal year concernedof twelve months; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that State unless of which the remuneration is derived by a resident person deriving the profits from the operation of the other Contracting Stateship or aircraft is a resident.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 1516, 17 18, 19 and 1820, salaries, wages and other similar remuneration remuneration, other than a pension, 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 within any twelve-month period commencing or ending in the fiscal year concerned; of 12 months, and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State State, may be taxed in that State. Where a resident of Sweden derives remuneration in respect of an employment exercised aboard an aircraft operated in international traffic by the air transport consortium Scandinavian Airlines System (SAS), such remuneration shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting StateSweden.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 151 6 , 17 1 8 and 181 9 , 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 therefore may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 , 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-twelve month period commencing or ending in the fiscal year concerned; period, and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship ship, aircraft or aircraft road or railway vehicle operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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 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 The remuneration is paid by by, or on behalf of of, an employer who is not a 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 by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident place of effective management of the other Contracting Stateenterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 17, 18, 19, 20 and 1821, 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 11 of this Article, 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 within any twelve-twelve month period commencing or ending in the fiscal year concerned; andperiod;
(b) the remuneration is paid by by, or on behalf of an employer a person 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 in respect of derived from an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting StateState of which the enterprise deriving the profits from the operation of ships or aircraft is a resident.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 and 1819, 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 exercisedexercised in the other Contracting State, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of in a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:if β
(a) the recipient is present in the other State for a period periods or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal year concernedperiod; and
(b) the remuneration is paid by by, or on behalf of 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 base, which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be taxed in the Contracting State shall be taxable only in that State unless of which the remuneration is derived by a resident person deriving the profits from the operation of the other Contracting Stateship or aircraft is a resident.
Appears in 1 contract
Sources: Double Taxation Relief Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 and 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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other Contracting State.
23. 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period period, or periods not exceeding in the aggregate 183 days in any twelve-month period 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 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. 5.
36. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State. 7.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, and 1820, 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 Contracting State, if:
(a) the recipient is present in the that other State for a period or periods not exceeding in the aggregate 183 91 days in within any twelve-month period commencing or ending in the fiscal year concernedtwelve months period; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 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 shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 and 18, 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 exercisedexercised in the other Contracting State, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, 1 of this Article remuneration derived by a resident of in 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 concernedperiod; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other State; and
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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxed in the Contracting State shall be taxable only in that State unless of which the remuneration is derived by a resident person deriving the profits from the operation of the other Contracting Stateship or aircraft is a resident.
Appears in 1 contract
Sources: Income Tax Treaty
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 and 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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other Contracting 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period period, or periods not exceeding in the aggregate 183 days in any twelve-month period 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 resident of the other Contracting State; and
(c) 3. the remuneration is not borne by a β permanent establishment or a fixed base which the employer has in the other Contracting State.
3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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 a remuneration as is derived therefrom may be taxed in that other Contracting 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 State, if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 91 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in the international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821 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 derived therefrom there from may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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-twelve month period commencing or ending in the fiscal year concerned; , and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19, 20 and 1821, 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 derived therefrom may be taxed in that other Contracting 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 ifif :
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal taxable year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise which is a resident of a Contracting State in international traffic shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
Sources: Agreement for Avoidance of Double Taxation of Income
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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 by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless State. However, if the remuneration is derived by a resident of the other Contracting State, it may also be taxed in that other State.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 15, 17 17, 18, 19 and 1820, 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 Contracting 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the fiscal calendar year concerned; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise which is a resident of a Contracting State in international traffic, shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 17, 18, 19 and 1820 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1, 1 of this Article 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 Contracting 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 by, or on behalf of of, an employer employer, who is not a 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 ship, aircraft or aircraft road vehicle operated in international traffic by an enterprise of a Contracting State shall in international traffic may be taxable only taxed in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 15, 17 16,18,19,20 and 1821, 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 by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, shall be taxed in the Contracting State shall be taxable only in that State unless which the remuneration is derived by a resident place of effective management (e.g. head office) of the other Contracting Stateenterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 17,18,19,20 and 1821, salaries, wages and other similar remuneration 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the relevant fiscal year concernedyear; and
(b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other Contracting State; and
(c) and 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 or land vehicle operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State unless the remuneration is derived by a resident of the other Contracting State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18 and 1819, 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-twelve month period commencing or ending in the fiscal year concerned; and
(b) the remuneration is paid by by, or on behalf of 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 in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable taxed only in that State unless State. However, if the remuneration is derived by a resident of the other Contracting State, it may also be taxed in that other State.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 17, 18, 19 and 1820 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 derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 11 of this Article, 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 within any twelve-month continuous period commencing or ending in the fiscal year concernedof twelve months; and
and (b) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other State; and
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 may be taxed in the Contracting State shall be taxable only in that State unless of which the remuneration is derived by a resident person deriving the profits from the operation of the other Contracting Stateship or aircraft is a resident.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1516, 17 18, 19 and 1820 of this Convention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment 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 11 of this Article, 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:
(a1) 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 concernedcalendar; and
(b2) the remuneration is paid by by, or on behalf of of, an employer who is not a resident of the other State; and
(c3) 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 traffic, or aboard a boat, may be taxed in the Contracting State shall be taxable only in that State unless of which the remuneration enterprise operating the ship, boat or aircraft is derived by a resident of the other Contracting Stateresident.
Appears in 1 contract