Article 15 - Income from Employment / Dependent Personal Services - International Taxation - Income Tax

Article 15 - Income from Employment / Dependent Personal Services As per OECD Model Tax Convention Confers Right of taxability of Income from Employment Subject to the provisions of Articles 16, 18 and 19, 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. [ Para 1 or Article 15 ] Exception 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 State for a period or periods not exceeding in the aggregate 183 days in any 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 State, and c) the remuneration is not borne by a permanent establishment which the employer has in the other State. [ Para 2 or Article 15 ] Confers Right of taxability of Income of Member of the Ship or aircraft Remuneration derived by a resident of a Contracting State in respect of an employment, as a member of the regular complement of a ship or aircraft , that is exercised aboard a ship or aircraft operated in international traffic, other than aboard a ship or aircraft operated solely within the other Contracting State, shall be taxable only in the first-mentioned State. [ Para 3 or Article 15 ] As per UN Model Tax Convention In the UN Model Only change the name of Article 15 other wise every thing is reproduces Article 15 of the OECD Model Convention.