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HMRC internal manual

Double Taxation Relief Manual

DT: Ivory Coast: double taxation agreement, Article 15: Dependent personal services

(1) Subject to the provisions of Articles 17,19,20 and 21, salaries, wages and othersimilar remuneration derived by a resident of a Contracting State in respect of anemployment shall be taxable only in that State unless the employment is exercised in theother Contracting State. If the employment is so exercised, such remuneration as isderived therefrom may be taxed in that other State.

(2) Notwithstanding the provisions of paragraph (1) of this Article, remunerationderived by a resident of a Contracting State in respect of an employment exercised in theother Contracting State shall be taxable only in 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, including normal interruptions in work, in any period of 12 months; 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) For the purpose of paragraph (2)(a) of this Article, `normal interruptions in work`means any period or periods during the twelve months in question for which the recipientis temporarily absent from that other State for purposes relating to his duties in thatState, including any period or periods of leave, provided the recipient was exercising anemployment in that State both before and after any such absence.

(4) Notwithstanding the preceding provisions of this Article, remuneration in respectof an employment exercised aboard a ship or aircraft operated in international traffic maybe taxed in the Contracting State in which the place of effective management of theenterprise is situated.