Article 15 - Dependent Personal Services

Taxation of employment income: resident-state taxation unless work is exercised in the source state, subject to limited exceptions.

Employment remuneration is taxable in the resident State unless the employment is exercised in the other Contracting State, where such remuneration may be taxed. Remuneration is taxable only in the resident State if the employee's presence in the other State does not exceed 183 days in the fiscal year, the employer is not a resident of the other State, and the remuneration is not borne by a permanent establishment or fixed base in that other State. If the remuneration is deductible against fees for technical services and the employer has no permanent establishment in the source State, source taxation may nonetheless apply, capped at 15%. Remuneration for employment on ships or aircraft in international traffic is taxable only in the enterprise's State.