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Old 14th Jul 2007, 19:55
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ELAC
 
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Obbie ...

The relevant section from the previous Tax Convention signed in 1979 read:
3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State, shall be taxable only in that State.
The 13 words "unless the remuneration is derived by a resident of the other Contracting State" that they added in to the new convention make all the difference.
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