Article 15 - Income from Employment
Article 15 sets the taxing rights for salaries earned by an employee of one State who works in the other.
Salaries derived by a resident of one State for employment exercised in the other State may be taxed in the State where the employment is exercised. The 183-day rule exempts source taxation where: (a) the employee is present for ≤183 days in the year, (b) salary is paid by an employer not resident in the source State, and (c) the salary is not borne by a PE of the employer in the source State.
Practical impact: Indian employees deputed to Poland for short assignments (≤183 days) typically continue to be taxed only in India, provided the employer remains Indian and there is no Indian-employer PE in Poland. Form 67 + TRC + Form 10F establish the position.