1. Subject to the provisions of Articles 15, 17 and 18, 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. If the employment
is so exercised, such remuneration as is derived therefrom may be taxed in that
other Contracting State.

2. Notwithstanding the provisions of paragraph 1, 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
Contracting State if:

  (a) the recipient is present in that other Contracting
  State for a period or periods not exceeding in the aggregate 183 days in any
  twelve month period commencing or ending in the taxable year concerned;

  (b) the remuneration is paid by, or on behalf of, an employer who is not a
  resident of that other Contracting State; and

  (c) the remuneration is not borne by a permanent establishment which the
  employer has in that other Contracting State.