SCHEDULE

Article 15 Dependent personal services
(2) Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a territory in respect of an employment exercised in the other territory shall be taxable only in the first-mentioned territory if:
(a) the recipient is present in the other territory 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
(b) the remuneration is paid by, or on behalf of, an employer who is not a resident of the other territory; and
(c) the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other territory.