租税条約：給与所得（Article 14）
令和7年10月31日|p.28
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ARTICLE 14
INCOME FROM EMPLOYMENT
1. Subject to the provisions of Articles15,17and18, 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 Contracting 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 Contracting State.
2. Notwithstanding the provisions of paragraph1, 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 Contracting State if:
(a) the recipient is present in the other Contracting State for a period or periods
not exceeding in the aggregate 183 days in any twelve month period
commencing or ending in the taxable year concerned, and
(b) the remuneration is paid by, or on behalf of, an employer who is not a
resident of the other Contracting State, and
(c) the remuneration is not borne by a permanent establishment which the
employer has in the other Contracting State.
3. Notwithstanding the preceding provisions of this Article, remuneration derived by
a resident of a Contracting State in respect of an employment, as a member of the regular
complement of a ship or aircraft, that is exercised aboard a ship or aircraft operated in
international traffic, other than aboard a ship or aircraft operated solely within the other
Contracting State, shall be taxable only in the first-mentioned Contracting State.