Artikel 15

1. Subject to the provisions of Articles 16, 18, 19, 20 and 21 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 Contracting State unless the employment is exercised in the other Contracting State. In this case, remuneration derived from such employment may be taxed in that other Contracting State if:
a) the recipient is present in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve month period commencing or ending in the fiscal year concerned, or
b) the remuneration is paid by, or on behalf of, an employer who is a resident of the other Contracting State, or
c) the remuneration is borne by a permanent establishment or a fixed base which the employer has in the other State.
2. Notwithstanding the preceding provisions of this Article, the remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft operating in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.