Debates Parlamentares - Diário 160S1, p. 395 (2014-08-23)

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ARTICLE 15

INCOME FROM EMPLOYMENT

1. Subject to the provisions of Articles 16, 18 and 19 of this Convention, 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 remu-

neration as is derived therefrom may be taxed in that other State.

2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi-

dent of a Contracting State in respect of an employment exercised in the other Contract-

ing 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 ex-

ceeding in the aggregate 183 days in any twelve month period commenc-

ing 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 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 may be taxed in the Contracting State in which the place of effective manage-

ment of the enterprise is situated.

ARTICLE 16

DIRECTORS' FEES

Directors' fees and other similar payments derived by a resident of a Contracting

State in his capacity as a member of the board of directors of a company which is a resi-

dent of the other Contracting State may be taxed in that other State.

ARTICLE 17

ARTISTES AND SPORTSMEN

1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resi-

dent of a Contracting State as an entertainer, such as a theatre, motion picture, radio or

television artiste, or a musician, or as a sportsman, from his personal activities as such

exercised in the other Contracting State, may be taxed in that other State.

23 DE AGOSTO DE 2014____________________________________________________________________________________________________________

395

ARTICLE 15 INCOME FROM EMPLOYMENT 1. Subject to the provisions of Articles 16, 18 and 19 of this Convention, 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 remu-neration as is derived therefrom may be taxed in that other State. 2. Notwithstanding the provisions of paragraph 1, remuneration derived by a resi-dent of a Contracting State in respect of an employment exercised in the other Contract-ing 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 ex-ceeding in the aggregate 183 days in any twelve month period commenc-ing 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 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 may be taxed in the Contracting State in which the place of effective manage-ment of the enterprise is situated. ARTICLE 16 DIRECTORS' FEES Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors of a company which is a resi-dent of the other Contracting State may be taxed in that other State. ARTICLE 17 ARTISTES AND SPORTSMEN 1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resi-dent of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State. 23 DE AGOSTO DE 2014____________________________________________________________________________________________________________395

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