(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 of which the enterprise operating the ship or aircraft is a resident.
3. Notwithstanding the provisions of paragraphs 1 and 2, 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 Contracting State.
Mr. GF,
Despite any advice you have already received from HM's revenue agency I would suggest you look further into your assumptions regarding article 15.
Above are two forms of the relevant passage frequently used in international tax treaties. Spot the difference? The one you have quoted is a newer form (check the date of the last treaty agreement between the states, then review the previous treaty) which was modified specifically to change the right of the contracting states to levy tax on crew from restrictive to permissive.
My experience over 15 years dealing with this article in relation to multiple treaties has been that tax accountants, and at times revenue service officials, will often provide advice that ultimately proves to be incorrect. Despite the reply you received, there is nothing in the form of the article you referenced that would inhibit the chancellor from requiring your contributions to the nation's welfare.
Given that you are considering a move to KE, a thorough double-check of your assumptions would be well advised. KE is a challenging enough employer even when you get to keep all the loot. When the wording in the treaty I was covered under there changed from the old to new form (10 years ago) it was time to leave. Those that remained have been paying their share to the Canadian version of HM's revenue agency ever since.
Regards,
ELAC