Poland-Netherlands (EN)

Article 15

Dependent personal services

1. Subject to the provisions of Articles 16, 18, 19, 20 and 21, 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 the first -mentioned State if:

1. 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
2. the remuneration is paid by, or on behalf of, an employer who is not a resident of the other State, and
3. 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 by a resident of a Contracting State in respect of an employment exer­cised aboard a ship or aircraft or a boat engaged in in­land waterways transport operated in international traffic, shall be taxable only in that State.