DT7315 - DT: France: double taxation agreement, Article 15 Dependent personal services
(1) Subject to the provisions of Articles 16, 18, 19 and 20,
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.
(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 State if:
(a) the recipient is present in the other State for a period or
periods not exceeding in the aggregate 183 days in any period of 12
months; and
(b) the remuneration is paid by, or on behalf of, an
employer who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent
establishment or a fixed base which the employer has in the other
State.
(3) 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 in which the place of effective management of the enterprise is situated.
