1. Subject to the provisions of Articles 16, 18 and 19, 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 the calendar year concerned, 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  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.