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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a resident.

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 Contracting State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any 12 consecutive months; twelve-month period commencing or ending in the taxable year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the that Contracting State of which the enterprise operating the ship or aircraft is a residentState.

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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive monthstwelve-month period commencing or ending in 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 this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may shall be taxed taxable only in the Contracting State of in which the place of effective management of the enterprise operating is situated. However, if the ship or aircraft remuneration is derived by a residentresident of the other Contracting State, it may also be taxed in that other Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; twelve month period commencing or ending in the fiscal year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other 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 by a resident of a Contracting State, in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of the other Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat other 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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned Contracting State if: (a) the recipient resident is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; 12-month period commencing or ending in 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 this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the by an enterprise of a Contracting State of which the enterprise operating the ship or aircraft is a residentshall be taxable only in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1615, 17, 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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State ifState: if the three following conditions are simultaneously met: (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 consecutive monthsthe 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 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 may be taxed in the that Contracting State of which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. (1. ) Subject to the provisions of Articles 16, 18, 19 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) of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; twelve-month period commencing or ending in the fiscal year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. (3. ) Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 17, 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive monthsthe relevant "previous year" or "year of income", as the case may be ; and (b) the remuneration is paid by, or on behalf ofon, an employer who is not a resident of the other Contracting StateState ; 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 may be taxed in the by an enterprise of a Contracting State of which the enterprise operating the ship or aircraft is a residentshall be taxable only in that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1818 and 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; twelve month period commencing or ending in the fiscal year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship ship, aircraft, road or aircraft railway vehicle operated in international traffic by an enterprise of a Contracting State, may be taxed in the that Contracting State of which the enterprise operating the ship or aircraft is a residentState.

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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-first- mentioned Contracting State if: (a) the recipient is present in the that other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; andtwelve month period commencing or ending in the tax year or taxable year concerned; (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 the that Contracting State of which the enterprise operating the ship or aircraft is a residentState.

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 there from may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any 12 consecutive months; twelve-months period commencing or ending in the taxable year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of derived from an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State of in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

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 ifif each of the following conditions is met: (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 consecutive months; twelve month period commencing or ending in the fiscal year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 and 2120 of this Convention, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 11 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; twelve month period commencing or ending in the fiscal year concerned of the other State, 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 the that Contracting State of which the enterprise operating the ship or aircraft is a residentState.

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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; twelve month period commencing or ending in the fiscal year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship ship, aircraft, rail-transport vehicle or aircraft road vehicle operated in international traffic by an enterprise of a Contracting State, may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat 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 ifif all the following conditions are met: (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 consecutive months; twelve-month period commencing or ending in the fiscal year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by a resident of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat 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 ifif : (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days within any twelve-month period commencing or ending in any 12 consecutive monthsthe 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 this Article, remuneration derived in respect of an employment exercised aboard a ship ship, aircraft and railway or aircraft road vehicle operated in international traffic may be taxed in the traffic, by an enterprise of a Contracting State of which the enterprise operating the ship or aircraft is a residentshall be taxable only in that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 1819, 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 employment Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-first- mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive monthstwelve- month period commencing or ending in the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship ship, aircraft, railway or aircraft road vehicle transport operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 17, 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive monthsthe relevant "previous year" or "year of income", 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 aircraft, operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 1819, 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State State, if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 90 days in any 12 consecutive monthstwelve-month period concerned; andand FBR, Government of Pakistan (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 by an enterprise of a Contracting State in international traffic may traffic, shall be taxed taxable only in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat 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 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 Contracting State State, for a period or periods not exceeding in the aggregate 183 one hundred and eighty-three days in any 12 consecutive months; andtwelve month period commencing or ending in the fiscal year 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 which is a resident of the other Contracting State may be taxed in the that Contracting State of which the enterprise operating the ship or aircraft is a residentState.

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-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 (one hundred eighty three) days in any 12 consecutive months; twelve-month period commencing or ending in the taxable year/year of income concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of derived from an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State of in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 1819, 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 exercisedexericed, 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 in 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive monthsthe " previous year " or " taxation 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 of the other Contracting State; and (c) c. the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration in derived by a resident of a Contracting State into respect of an employment exercised aboard abroad a ship or aircraft operated in international traffic may shall be taxed taxable only in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 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 11 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive monthstwelve-month period commencing or ending in the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State of in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

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 Contracting State for a period or periods not exceeding in the aggregate 183 days days (i) in any 12 consecutive monthsthe case of Myanmar in the fiscal year concerned; and (ii) in the case of Thailand in the taxable year 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 resident of the other Contracting State or a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship vessel, aircraft or aircraft vehicle operated in international traffic may be taxed in the by an enterprise of a Contracting State of which the enterprise operating the ship or aircraft is a residentshall be taxable only in that State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 17, 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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; andthe relevant "previous year" or "taxable period," as the case may be; (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 deductible in computing the profits or income of a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 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 11 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State ifif : (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive monthstwelve-month period commencing or ending in the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic traffic, or aboard a boat engaged in inland waterways transport, may be taxed in the Contracting State of in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

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 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 consecutive months; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a resident.

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 Contracting State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-first- mentioned Contracting State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; andtwelve month period commencing or ending in the taxable year 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 the that Contracting State of which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 1819, 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, 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 consecutive months; twelve month period commencing or ending in the taxable year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the by an enterprise of a Contracting State of which the enterprise operating the ship or aircraft is a residentshall be taxable only in that Contracting State.

DEPENDENT PERSONAL SERVICES. 1. Subject Without prejudice to the provisions of Articles 16, 17, 18, 19 and 21, salaries19, wages and other types of similar remuneration derived received by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the such employment is exercised in the other Contracting State. If In case the employment is so exercised, such remuneration as is derived therefrom may received therefor can be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived obtained 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 one hundred and eighty-three days during any twelve-month period commencing or ending during the fiscal year in any 12 consecutive months; question, 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 place of business which the employer has in the other Contracting State. 3. Notwithstanding the The preceding provisions of this ArticleArticle notwithstanding, remuneration obtained in respect of an employment exercised aboard a ship or aircraft operated by an enterprise in international traffic may be taxed in the that Contracting State of which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 17, 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 there from may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if:if:-- (a) a. the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; andthe relevant "previous year" or "taxable period", as the case may be; (b) b. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) c. the remuneration is not borne by deductible in computing the profits or income of a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Articlearticle, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat 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 Stale 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, . 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 Stale for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any 12 consecutive months; twelve-month period commencing or ending in the calender year concerned, and (b) the remuneration is paid by, . or on behalf of, . an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of derived from an employment exercised aboard on board a ship or aircraft operated in international traffic may be taxed in the Contracting State of in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

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 there from may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-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 (one hundred eighty three) days in any 12 consecutive months; twelve-month period commencing or ending in the calender year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, . remuneration in respect of derived from an employment exercised aboard on board a ship or aircraft operated in international traffic may be taxed in the Contracting State of in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

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 Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; twelve month period commencing or ending in the fiscal year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other 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 on ship, aircraft, railway or aircraft road vehicles operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to Taking into account the provisions of Articles Article 16, 18, 19 and 2119, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of connection with an employment shall be taxable only in that State unless the employment is exercised in the other Contracting StateState . If the employment is so exercised, such remuneration as is derived therefrom the consideration received in connection with this, 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 consecutive months; twelve month period commencing or ending in the fiscal year, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of connection with an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentaircraft.

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 ifif : (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; the calendar year concerned in the case of Turkey and 183 days in the financial year concerned in the case of India, 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 traffic, may be taxed in the Contracting State of in which the registered office of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1818,19, 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 ifif all the following conditions are met: (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 consecutive months; andtwelve month period commencing or ending in the calendar year 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 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 may be taxed in the that Contracting State of which the enterprise operating the ship or aircraft is a residentState.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 18, 19 19, and 21, wages, 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 In case 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 not present in the other Contracting State for a period or periods not exceeding in the aggregate 183 one hundred and eighty-three days during any twelve-month period commencing or ending during the fiscal year in any 12 consecutive months; question, 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 The preceding provisions of this ArticleArticle notwithstanding, remuneration obtained in respect of an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State where the place of which effective management of the enterprise operating the ship or aircraft is a residentlocated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 1818,19, 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 that other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; twelve month period commencing or ending in the fiscal year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the 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 traffic, by an enterprise of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16, 17, 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-first- mentioned State State, if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive months; andthe relevant "previous year" or "taxable period," as the case may be; (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 deductible in computing the profits or income of a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat 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 Contracting State for a period or periods not exceeding in the aggregate 183 (one hundred eighty three) days in any 12 consecutive months; twelve-month period commencing or ending in the taxable year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; , and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of derived from an employment exercised aboard a ship or aircraft operated in international traffic may be taxed in the Contracting State of in which the place of effective management of the enterprise operating the ship or aircraft is a residentsituated.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 1617, 1819, 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 employment Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-first - mentioned State if: (a) the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any 12 consecutive monthstwelvemonth period commencing or ending in the fiscal year concerned; and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship ship, aircraft, railway or aircraft road vehicle transport operated in international traffic by an enterprise of a Contracting State may be taxed in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat State.

DEPENDENT PERSONAL SERVICES. 1. Subject to the provisions of Articles 16articles 17, 1819, 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 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 consecutive monthsthe "previous year" or "taxation 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 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 Articlearticle, remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft operated in international traffic may shall be taxed taxable only in the Contracting State of which the enterprise operating the ship or aircraft is a residentthat 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 StateSlate. 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 1I, 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 (one hundred eighty three) days in any 12 consecutive months; twelve-month period commencing or ending in the taxable year concerned, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting StateSlate; 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 on board a ship or aircraft operated in international traffic traffic, may be taxed in the Contracting State of in which the enterprise operating profits from the ship operation of the ships or aircraft is a residentare taxable according to the provisions of Article 8.