Article 16 - Dependent personal services - UAR (Egypt)

ARTICLE 16 DEPENDENT PERSONAL SERVICES 1. Subject to the provisions of articles XVII, XIX and XX, 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 is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph (1) remuneration derived by a resident of the United Arab Republic in respect of an employment exercised in India shall not be taxed in India, if (a) he is present in India for a period or a periods not exceeding in the aggregate 183 days during the relevant previous year, and (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of India, and (c) the remuneration is subject to United Arab Republic tax, and (d) the remuneration is not deducted in computing profits of an enterprise chargeable to Indian tax. 3. Notwithstanding the provisions of paragraph (1) remuneration derived by a resident of India in respect of an employment exercised in the United Arab Republic shall not be taxed in the United Arab Republic, if (a) he is present in the United Arab Republic for a period or periods not exceeding in the aggregate 183 days during the relevant fiscal year, and (b) the remuneration is paid by, or on behalf of an employer who is not resident of the United Arab Republic, and (c) the remuneration is subject to Indian tax, and (d) the remuneration is not deducted in computing profits of an enterprise chargeable to United Arab Republic tax. 4. Notwithstanding the preceding provisions of this article, remuneration in respect of an employment exercised aboard a ship or aircraft in international traffic, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.