Dependent personal services: remuneration generally taxed in resident state unless employment exercised abroad, subject to presence and employer conditions.

Article 15 provides that remuneration for dependent personal services is taxable in the resident State unless the employment is exercised in the other Contracting State, in which case that other State may tax the remuneration. The treaty prevents source state taxation where the employee's presence in the other State does not exceed the treaty's allowable presence period, the remuneration is paid by an employer who is not resident in the other State, and the remuneration is not borne by a permanent establishment or fixed base of the employer in the other State. Remuneration from employment aboard ships or aircraft in international traffic may be taxed in the State of the enterprise.

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