Common use of DEPENDENT PERSONAL SERVICES Clause in Contracts

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month period, 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 any employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State State, if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month period, the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, ; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1619, 1820, 19 and 21, 21 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State ifif : (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in within any 12twelve-month period, 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 Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 18 and 2119, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in within any 12twelve-month period, ; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month periodthe calendar 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, 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 State for a period or periods not exceeding in the aggregate 183 days in within any 12-month period, taxable year; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 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, exercised such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State ifState, if : (a) the recipient is present in the that other State for a period or periods not exceeding in the aggregate 183 days in within any 12-twelve month period, ; 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 any 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.

DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18, 19 19, 20 and 21, 21 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. (2. ) Notwithstanding the provisions of paragraph (1), remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month period, the calendar 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 any an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise which is a resident of a Contracting State may be taxed in that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 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 Contrcating State. If the employment is so exercised, exercised such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting Contrcating 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 State for a period or periods not exceeding in the aggregate anggregate 183 days in within any 12-twelve month period, ; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1817, 19 , 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State ifif : (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month period, the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, ; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of any an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may shall be taxed only in that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in within any 12-month periodperiod of twelve months, 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 any an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State in international traffic, may be taxed in that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned firstmentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12-month period, the calendar 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 paragraphs 1 and 2 of this Article, remuneration derived in respect of any an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State in international traffic, may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, 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 State for a period or periods not exceeding in the aggregate 183 days in within any 12-month period, taxable year; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, 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 State for a period or periods not exceeding in the aggregate 183 days in any 12-month period, the calendar year; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20, and 21, 21 salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period period, or periods not exceeding in the aggregate 183 days in any 12-month period, the fiscal 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, 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 90 days in within any 12twelve-month period, 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, 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 State for a period or periods not exceeding in the aggregate 183 days in any 12-month period, calendar year; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 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 11 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days within in any 12-twelve month period, 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month period, the calendar 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 any an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State in international traffic may be taxed in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, 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 State for a period or periods not exceeding exceeding, in the aggregate 183 days in within any 12-month twelve months period, ; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, 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 State for a period or periods not exceeding in the aggregate 183 days in within any 12-twelve month period, ; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19,20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month period, the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, ; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provisions of paragraphs 1 and 2 of this Article, remuneration derived in respect of any an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise which is a resident of a Contracting State may in international traffic, shall be taxed taxable only in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in within any 12-twelve month period, 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 any 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 in that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19t and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State 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 within any 12-twelve month period, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the that 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-twelve month period, ; and (b) the remuneration is not 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1817, 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, 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 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 within any 12twelve-month period, ; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in within any 12-twelve month period, ; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, 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 within any 12twelve-month period, ; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 18 and 2119, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a1) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-twelve month periodperiod commencing or ending in the fiscal year concerned, and (b2) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and (c3) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18, 19 19, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month periodthe relevant “taxable year”, 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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 arrived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the that other State for a period or periods not exceeding in the aggregate 183 days in within any 12twelve-month period, ; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month periodthe fiscal year concerned of that other State, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and (and c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 18, 19 19, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) a. the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any 12-month periodthe relevant " taxable year ", 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State 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 within any 12-month period, period of 12 months; 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 any 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.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 1819, 19 20, and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12-month period, the year of assessment 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 resident or a permanent establishment or a fixed base which the employer has in the other State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of any an employment exercised aboard abroad a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in within any 12-twelve month period, 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 any 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 in that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State State, if: (a) the recipient is present in the that other State for a period or periods not exceeding in the aggregate 183 90 days in within any 12-month period, period of 12 months; 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 any 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.