DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is 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 if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment or in the taxable period, as the case may be; 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 may be taxed in that State.
Appears in 6 contracts
Sources: Avoidance of Double Taxation Agreement (Dta), Double Taxation Agreement, Avoidance of Double Taxation Agreement (Dta)
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodcalendar year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.
Appears in 6 contracts
Sources: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 18 and 2119 of this Agreement, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is 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 if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or an aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 4 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 16, 18, 19, 20 19 and 2120, 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 of this Article1, 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 the year of assessment or in the taxable any twelve-month period, as the case may be; 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 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.
Appears in 4 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 16, 18, 19, 20 19 and 2120, 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 of this Article1, 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 the year of assessment any twelve-month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.
Appears in 4 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 16, 1817, 19, 20 20, 21 and 2122, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve months period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise of a Contracting State may be taxed in that State.
Appears in 4 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 16, 1817, 19, 20 20, 21 and 21, 22 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(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 the basis year or the relevant year of assessment or in the taxable periodincome, as the case may be; 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 resident of the other Contracting State 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 may be taxed in that State.
Appears in 4 contracts
Sources: Double Taxation Avoidance Agreement, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise 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 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 3 contracts
Sources: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Income and Capital Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a shall be taxable only in the Contracting State in which the place of effective management of the enterprise 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 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 16, 18, 19, 20 19 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 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship ship, aircraft or aircraft vehicle operated in international traffic by an enterprise of a Contracting State State, may be taxed in that State.
Appears in 3 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, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 may be taxed in that State.
Appears in 3 contracts
Sources: Double Taxation Avoidance 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 16, 18, and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall 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 Article1, 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 the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may befiscal 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 may be taxed in that State.
Appears in 3 contracts
Sources: Agreement Between the Government of the Republic of Indonesia and the Government of the Republic of South Africa 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 South Africa 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 South Africa 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 16, 18, 19, 20 19 and 2120, 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 may be taxed in that State.
Appears in 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement, Income Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 3 contracts
Sources: Agreement for the Avoidance of Double Taxation and Prevention of Fiscal Evasion, Double Taxation Agreement, Convention for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise of a Contracting State may be taxed in that State.
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 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodyear concerned, as the case may be; 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 derived in respect re- spect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Statethe Contracting State in which the place of effective management of the en- terprise is situated.
Appears in 3 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement, Agreement for the Avoidance of Double Taxation
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period Commencing or ending in the taxable period, as the case may befiscal 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 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 taxable in that 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 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 concerned in any period of twelve consecutive months commencing or ending in the fiscal year of assessment or in the taxable periodconcerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
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 16, 1817, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion, Income and Capital Gains Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1817, 19, 20 20, 21 and 2122, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 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 may be taxed in that 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 16, 18, 19, 20 19 and 2120, 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 Article1, 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 State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal year concerned; and
(b) the remuneration is paid by, or on behalf 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 may be taxed in that State.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Income Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1616,18, 18, 19, 19 and 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 of this Article1, 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 (one hundred eighty three) days in the year of assessment any twelve month period commencing or ending in the taxable periodyear concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 2 contracts
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
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 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 (one hundred eighty three) days in the year of assessment any twelve-month period commencing or ending in the taxable periodcalender year concerned, as the case may be; 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 derived from an employment exercised aboard on board a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise 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 16, 18, 19, 20 19 and 2120, 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 Article1, 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 concerned in any period of twelve consecutive months commencing or ending in the fiscal year of assessment or in the taxable periodconcerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship ship, aircraft, road vehicle or aircraft railway operated in international traffic by an enterprise of a Contracting State may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
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 16, 18, 19, 20 19 and 2120, 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a may be taxable in the Contracting State may be taxed in that Statewhich the place of effective management of the enterprise 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 16, 18, 19, 20 19 and 2120, 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 Article1, 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 within any twelve-month period commencing or ending in the calendar year of assessment or in the taxable periodconcerned, as the case may be; and
(b) b. the remuneration is paid by, or on behalf 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 may be taxed in that 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 16, 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 exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise which operates the ship or aircraft is situated.
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 16, 18, 19, 20 19 and 2120, 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any 12-month period commencing or ending in the taxable period, as the case may befiscal year concerned; and
(b) the remuneration is paid 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 may be taxed in that Statethe Contracting State in which the place of effective management 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 16, 18, 19, 20 19 and 2120, 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 of this Article1, 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 the calendar year of assessment or in the taxable period, as the case may beconcerned; 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 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 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 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 all the following conditions are met:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.
Appears in 2 contracts
Sources: Agreement for the Avoidance of Double Taxation, Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by 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 Nowithstanding the provisions of paragraph 1 of this Article1, 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 the 3 following conditions are simultaneously fulfilled:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the calendar year of assessment or in the taxable period, as the case may beconcerned; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Statethe Contracting State in which the place of head office of the enterprise 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 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 an aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that 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 16, 18, 19, 20 19 and 2120, 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 Article1, 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 the year of assessment any twelve month period commencing or ending in the taxable periodperiod concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
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 16, 1817, 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 of this Article1, 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 the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may becalendar 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
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 16, 1817, 19, 20 20, 21 and 2122, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 provision 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 only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
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 16, 18, 19, 20 19 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 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 2 contracts
Sources: Convention for the Avoidance of Double Taxation, Income and Capital Gains Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18, 19, 20 20, 21 and 2122, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 the relevant "previous year" or "year of assessment or in the taxable periodincome", as the case may be; andbe ;
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
Sources: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State of which the enterprise operating the ship or aircraft is a resident.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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 of this Article1, 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 within any twelve-month period commencing or ending in the fiscal year of assessment or in the taxable periodconcerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise of a Contracting State may shall be taxed taxable only in that State.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by 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 Article1, 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 within any twelve - month period commencing or ending in the calendar year of assessment or in the taxable periodconcerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable taxble only in the first-mentioned Contracting State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal year concerned; and
(b) the remuneration is paid by, or on behalf 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 may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration remune ration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve -month period commencing or ending in the taxable period, as the case may befiscal 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 may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by 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 Article1, 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 the year of assessment any twelve-month period commencing or ending in the taxable periodcalendar year concerned, as the case may be; and
(b) b. the remuneration is paid by, or on behalf 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 may be taxed in that Contracting State.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18, 19, 20 and 2120, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable periodcalendar year concerned, as the case may be; 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 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 State, may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall shal 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall shal be taxable only in the first-mentioned firstmentioned State if:
(aa ) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; and
(bb ) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(cc ) 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 traf ic, by an enterprise of a Contracting State may be taxed in that Statethe Contracting State in which the place of ef ective management of the enterprise is situated.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 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 days in the year of assessment or in the taxable periodtwelve-month period concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship ship, boat or aircraft operated in international traffic by an enterprise of a Contracting State State, may be taxed in that Contracting State.
Appears in 1 contract
Sources: Income and Capital Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 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 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by 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 Article1, 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 the calendar year of assessment or concerned in the taxable period, as case of Turkey and 183 days in the financial year concerned in the case may be; of India, and
(b) b. the remuneration is paid by, or on behalf 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 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 traffic, may be taxed in that Statethe Contracting State in which the registered office of the enterprise is situated.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18, 19, 20 20, 21 and 2122, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect repect 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised exercied in the other Contracting State shall be taxable only in the first-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 the relevant "previous year" or "year of assessment or in the taxable periodincome", as the case may be; and
(b) b. the remuneration is paid by, or on behalf 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 may be taxed in that State.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18, 19, 20 20, 21 and 2122, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may beand; and]
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other StateState ; 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 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 may be taxed in that State.
Appears in 1 contract
Sources: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve -month period commencing or ending in the taxable period, as the case may befiscal 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 ArticleArt icle, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic International traffic, by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 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 exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the relevant "previous year" or "year of assessment or in the taxable periodincome", as the case may be; and
(b) b. the remuneration is paid by, or on behalf 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 may shall be taxed taxable only in that State.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a shall be taxable only in the Contracting State in which the place of effective management of the enterprise is situated. However, if the remuneration is derived by a resident of the other Contracting State, it may also be taxed in that State.other State.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18, 19, 20 19 and 2120, 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve (12) month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 within any twelve-month period commencing or ending in the fiscal year of assessment or in the taxable periodconcerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
Sources: Double Taxation Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise of a Contracting State State, may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 resident is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period, commencing or ending in the taxable period, as the case may becalendar 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may shall be taxed taxable only in that Contracting State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1616 (Directors’ Fees and Remuneration of Managerial Officials), 1818 (Pensions), 19, 19 (Government Services) and 20 (Professors and 21, Students) 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodperiod concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship ship, boat, aircraft, road or aircraft railway vehicle operated in international traffic by an enterprise of a Contracting State State, may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 of this Article1, 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 the year of assessment or in the taxable period, as the case may beany twelve month period 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 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 may in international traffic, shall be taxed taxable only in that Statethe Contracting State in which the place of head office or effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by 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 of this Article1, 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 the year of assessment or in the taxable any twelve-month period, as the case may be; 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 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.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; and
(b) the remuneration is paid by, or on behalf 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 may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 18 and 21, 19 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 (one hundred eighty three) days in the year of assessment any twelve-month period commencing or ending in the taxable periodcalendar year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may State, shall be taxed taxable only in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may be; andtax year concerned of that other State,
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; , and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 19 and 20 and 21, 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 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may beperiod concerned; and
(b) the remuneration is paid 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 may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1817, 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 of this Article1, 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:: FBR, Government of Pakistan
(a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in the calendar year of assessment or in the taxable period, as the case may beconcerned; 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 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 may in international traffic shall be taxed taxable only in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
Sources: Income Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 18 and 2119 of this Agreement, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 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 and ground staff shall be taxable only in the Contracting State may be taxed in that Stateof which the enterprise operating the ship or aircraft is a resident.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
Sources: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration remun eration 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 e xceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 b orne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 18 and 2119 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 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship ship, boat or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that the Contracting State, of which the enterprise operating the ship, boat or aircraft is a resident.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 21, 20. 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a traffic, may be faxed in the Contracting State may be taxed in that Statewhich the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised exercised, in the other Contracting StateState . If the employment is so exercised, such remuneration as is derived therefrom there from may be taxed in that other StateState .
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve months period commencing or ending in the taxable periodfiscal year concerned, as the case may be; and
(b) the remuneration is paid by, 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 establish-ment or a fixed base base, which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State in which the profits from the operation of the ship 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 16, 18, 19, 20 19 and 2120, 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 Article1, 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 each of the following conditions is met:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment or in the taxable any consecutive twelve-month period, as the case may be; 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 derived in respect of an employment exercised aboard a ship ship, aircraft or aircraft road-transport vehicle operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State in which the enterprise operating the ship, aircraft or road-transport vehicle is a resident.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 remuneration's derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a shall be taxable only in the Contracting State may be taxed in that Statewhich the place of head office (place of effective management) of the enterprise is situated.
Appears in 1 contract
Sources: Income Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1817, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present represent in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
Sources: Income Tax Treaty
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 of this Article1, 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) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may be; andyear concerned;
(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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Contracting State.. Article 16
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived denied 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 ArticleParagraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment taxable period or in the taxable periodfiscal year, as the case may be; , of that State, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; 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, may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
Sources: Income Tax Convention
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by 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 of this Article1, 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 the year of assessment or in the taxable any twelve-month period, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 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.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
Sources: Income Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident re sident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve -month period commencing or ending in the taxable period, as the case may befiscal 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 est ablishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 18 and 21, 19 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 (one hundred eighty three) days in the year of assessment any twelve-month period commencing or ending in the taxable periodcalendar year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may State, shall be taxed taxable only in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1817, 19, 20 and 2122, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that 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 of this Article1, 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 that other Contracting State for a period or periods not exceeding in the aggregate 183 90 days in the year of assessment or in the taxable period, as the case may beany twelve-month period 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 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 may in international traffic shall be taxed taxable only in that State.
Appears in 1 contract
Sources: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1817, 19, 20 and 2121 of this Agreement, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 the year of assessment any twelve month period commencing or ending in the taxable periodyear concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may shall be taxed taxable only in that Contracting State.
Appears in 1 contract
Sources: Income Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, 21 salaries, wages and other similar remuneration derived by a resident of a Contracting State 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 19 and 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 of this Article1, 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 (one hundred eighty three) days in the year of assessment any twelve month period commencing or ending in the taxable periodyear concerned, as the case may be; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may shall be taxed taxable only in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 19 and 2120, salaries, wages and other similar remuneration derived by 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 if:
(a) the recipient is present in the other State for a period or periods periods-including normal interruptions of work- not exceeding in the aggregate 183 days in the fiscal year of assessment or in the taxable period, as the case may beconcerned; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Statethe Contracting State in which the place of effective management of the enterprise is situated.
Appears in 1 contract
Sources: Tax Treaty
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State 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 if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve-month period commencing or ending in the taxable period, as the case may be; andfiscal year concerned;
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may State, shall be taxed taxable only in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 1817, 19, 20 and 2121 of this Convention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is 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 State for a period or periods not exceeding in the aggregate 183 days in the year of assessment any twelve month period commencing or ending in the taxable period, as the case may befiscal 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that Statethe Contracting State of which the enterprise operating the ship or aircraft is a resident.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that Contracting State unless the employment is exercised 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 of this Article1, 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 the fiscal year of assessment or in the taxable period, as the case may beconcerned; 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 derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State traffic, may be taxed in that Statethe Contracting State of which the enterprise is a resident.
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Sources: Income Tax Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 18 and 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2. Notwithstanding the provisions of paragraph 1 of this Article1, 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 the year of assessment any twelve month period commencing or ending in the taxable periodfiscal year concerned, as the case may be; and
(b) the remuneration is paid by, or on behalf of, a person being 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 person being an 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 may be taxed in that State.
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Sources: Double Taxation Avoidance Agreement
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1620 (Pensions, 18Annuities, 19Alimony, 20 and 21Child Support) and 21 (Government Service), salaries, wages 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 Article1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in the year of assessment or in the taxable any 12 month period, as the case may be; 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 derived in respect of an employment exercised aboard as a member of the regular complement of a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.
Appears in 1 contract
DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19, and 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 of this Article1, 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 within any twelve-month period commencing or ending in the fiscal year of assessment or in the taxable periodconcerned, as the case may be; 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 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.
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Sources: Agreement for Avoidance of Double Taxation and Prevention of Fiscal Evasion