DT6720.15 - DT: Estonia: double taxation agreement, Article 15: Dependent personal services
- Subject to the provisions of Articles 16, 18, 19, 20 and 21 of
this Convention, 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.
- 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 be taxable only in the first- mentioned State if:
- 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
- the remuneration is paid by, or on behalf of, an employer who
is not a resident of the other State, and
- the remuneration is not borne by a permanent establishment or a
fixed base which the employer has in the other State.
- Notwithstanding the preceding provisions of this Article,
remuneration derived in respect of an employment exercised aboard a
ship or aircraft operated in international traffic by an enterprise
of a Contracting State may be taxed in that State.
