DT3878 - Botswana: double taxation agreement,
Article 14: Dependent personal services
This agreement applies for periods before the new
comprehensive agreement has effect (see DT3850).
- 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 may be taxed in that
State. However, if the employment is exercised in whole or in part
in the other Contracting State then, to the extent that the
employment is so exercised, such remuneration as is derived
therefrom may also be taxed in that other State.
- Notwithstanding the provisions of paragraph (1) of this Article
remuneration derived by a resident of a Contracting State in
respect of an employment exercised in the other Contracting State
shall not be taxed in that other State if:
- the recipient of the remuneration is present in that other
State for a period or periods not exceeding in the aggregate 183
days in the fiscal year concerned; and
- the remuneration is paid by, or on behalf of, an employer who
is a resident of the first-mentioned State; and
- the remuneration is subject to tax in the first-mentioned
State.
- 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 of which the person deriving the profits from the operation
of the ship or aircraft is a resident.
