МЕЖДУ ПРАВИТЕЛЬСТВОМ РОССИЙСКОЙ ФЕДЕРАЦИИ И ПРАВИТЕЛЬСТВОМ БОЛИВАРИАНСКОЙ РЕСПУБЛИКИ ВЕНЕСУЭЛА ОБ ИЗБЕЖАНИИ ДВОЙНОГО НАЛОГООБЛОЖЕНИЯ И ПРЕДОТВРАЩЕНИИ УКЛОНЕНИЯ ОТ НАЛОГООБЛОЖЕНИЯ В ОТНОШЕНИИ НАЛОГОВ НА ДОХОДЫ И КАПИТАЛ. Конвенция. Правительство РФ. 22.12.03

Article 15
                     Dependent personal services

     1. Subject to the provisions of Articles 16, 18 and 19, salaries,
wages  and  other  similar  remuneration  derived  by  a resident of a
Contracting State in respect of an employment shall be taxable only in
that State unless the employment is exercised in the other Contracting
State.  If  the  employment  is  so exercised, such remuneration as is
derived therefrom may be taxed in that other State.
     2.  Notwithstanding  the  provisions of paragraph 1, remuneration
derived  by  a  resident  of  a  Contracting  State  in  respect of an
employment  exercised  in the other Contracting 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 any twelve month
period commencing or ending 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 or
a fixed base which the employer has in the other State.
     3.  Notwithstanding  the  preceding  provision  of  this Article,
remuneration  derived  in  respect of an employment exercised aboard a
ship or aircraft operated in international traffic by an enterprise of
a  Contracting  State  shall be taxed only in the Contracting State of
which the enterprise is a resident.