ARTICLE 15

Dependent Personal Services

This Article generally provides that, subject to the provisions relating to directors' fees (Article 16), pensions and annuities (Article 18) and government services (Article 19), remuneration derived by a resident of a Contracting State in respect of an employment may be taxed only by that State unless and to the extent that such remuneration is for employment exercised in the other Contracting State, in which case the latter State may also tax such remuneration. Even if the employment is exercised in the other Contracting State, however, such remuneration is taxable only in the person's State of residence if four conditions are met:

(1) his remuneration in the taxable year from such employment in the other State is not more than $5,000 (or its equivalent in Barbadian currency);

(2) he is present in the other State for not more than 183 days in the calendar year; (3) he is paid by, or on behalf of, an employer who is not a resident of the other State; and (4) the remuneration is not deductible in computing taxable income of a permanent establishment or regular base of the employer in the other State.

Paragraph 3 provides a special rule for remuneration derived by members of the regular complement of ships or aircraft operated in international traffic. Such remuneration is taxable only by the Contracting State of which the employee is resident.

This Article is subject to the provisions of the saving clause of paragraph 3 of Article 1 (General Scope).