Article 14 - Professional services - Greece

ARTICLE 14 PROFESSIONAL SERVICES 1. Profits or remuneration for professional services or for services as an employee (including services as a director) performed in one of the territories by an individual who is a resident of the other territory may be taxed only in the territory in which such services are performed. 2. An individual who is a resident of India shall not be taxed in Greece on profits or remuneration referred to in paragraph (1) if (a) he is temporarily present in Greece for a period or periods not exceeding in the aggregate 183 days during the calendar year immediately preceding the relevant fiscal year, (b) the services are performed for or on behalf of a resident of India, (c) the profits or remuneration are subject to Indian tax, and (d) the profits or remuneration are not deducted in computing the profits of an enterprise chargeable to Greek tax. 3. An individual who is a resident of Greece shall not be taxed in India on the profits or remuneration referred to in paragraph (1) if (a) he is temporarily present in India for a period or periods not exceeding in the aggregate 183 days during the relevant previous year , (b) the services are rendered for or on behalf of a resident of Greece, (c) the profits or remuneration are subject to Greek tax, and (d) the profits or remuneration are not deducted in computing the profits of an enterprise chargeable to Indian tax. 4. Where an individual permanently or predominantly performs services on ships or aircraft in international traffic operated by an enterprise of one of the territories, profits or remuneration from such services may be taxed only by the country of which the individual is resident.