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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: Trinidad and Tobago: double taxation agreement, Article 15 Dependent personal services

(1) Subject to the provisions of Articles 16, 18, 19 and 20, 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, remuneration derivedby a resident of a Contracting State in respect of an employment exercised in the otherContracting 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 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 which the employer has in the other State.

(3) Notwithstanding the preceding provisions of this Article, remuneration derived inrespect of an employment exercised aboard a ship or aircraft operated in internationaltraffic may be taxed in the Contracting State in which the place of effective managementof the enterprise is situated.