Artikel 4

1. Remuneration derived in respect of an employment exercised abroad an aircraft operated in international traffic shall be taxable only in the Contracting State in which the air transport enterprise is situated.
2. Remuneration derived by an employee of an air transport enterprise of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in that other State, unless the employee is a national of the first-mentioned State. In that case, such remuneration shall be taxable only in the first-mentioned State, provided that the number of such employees shall not exceed two and the period of time during which they reside in the other State, does not exceed five years. The date on which this Agreement will become effective is the date on which the first period of five years will commence. The social security legislation of the other State shall not be applicable to such employees; consequently they cannot derive rights from that legislation.