- 1
- Subject to the provisions of Articles 16, 18, 19 and 20 salaries, wages and other similar remuneration derived by a resident of one of the States in respect of an employment shall be taxable only in that State unless the employment is exercised in the other 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 one of the States in respect of an employment exercised in the other 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 calendar year concerned, and
- b)the remuneration is paid by, or on behalf of, a person who is not a resident of the other State, and
- c)the remuneration is not borne by a permanent establishment or a fixed base which that person has in the other State.
- 3
- Notwithstanding the provisions of paragraphs 1 and 2 of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft in international traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the State in which the place of effective management of the enterprise is situated.
- 4
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- a)Notwithstanding the provisions of paragraph 1 of this Article, salaries, wages and other similar remuneration, paid by one of the States or a political subdivision or a local authority thereof to an individual may be taxed in that State;
- b)However, such salaries, wages and remuneration shall be taxable only in the other State if the activities are exercised in that other State and the recipient is a resident of that other State who:
- (1)is a national of that other State; or
- (2)did not become a resident of that other State solely for the purpose of exercising the activities.
- 5
- Notwithstanding the provisions of paragraph 4 of this Article the provisions of paragraphs 1, 2 and 3 of this Article shall apply to salaries, wages and other similar remuneration in respect of activities exercised in connection with a business carried on by one of the States or a political subdivision or a local authority thereof.
