TREATIES taxable only in the contracting State in which such property, mines, quarries, or other natural resources are situated. (2) A resident or corporation of one of the contracting States deriving any such income from sources within the other contracting State may, for any taxable year, elect to be subject to the tax of such other contracting State, on a net basis, as if such resident or corpora- tion were engaged in trade or business within such other contracting State through a permanent establishment therein during such taxable year. Article X W et., tax ex- (1) Wages, salaries, and similar compensation and pensions paid by one of the contracting States or by any other public authority within that State to individuals residing in the other State shall be taxable only in the former State. crivate pensions, (2) Private pensions and life annuities derived from within one of the contracting States and paid to individuals residing in the other contracting State shall be exempt from taxation in the former State. "Llfeannuities" (3) The term "life annuities" as used herein means a stated sum payable periodically at stated times during life, or during a specified number of years, under an obligation to make the payments in con- sideration of a gross sum paid for such obligation. Article XI Compensation for ( omnst abor or person serv- (1) Compensation for labor or personal services, including the ic es . practice of the liberal professions, shall be taxable only in the con- tracting State in which such services are rendered. Exceptons. (2) The provisions of paragraph (1) are, however, subject to the following exceptions: (a) A resident of Denmark shall be exempt from United States tax upon compensation for labor or personal services if he is tem- porarily present in the United States for a period or periods not exceeding a total of ninety days during the taxable year and the compensation received for such services does not exceed $3,000 in the aggregate. If, however, his compensation is received for labor or personal services performed as an employee of, or under contract with, a resident or corporation or other entity of Denmark, he will be exempt from United States tax if his stay in the United States does not exceed a total of 180 days during the taxable year. (b) The provisions of paragraph (2) (a) of this Article shall apply, mutatis mutandis, to a resident of the United States with respect to compensation for personal services otherwise subject to income tax in Denmark. (3) The provisions of this Article shall have no application to the income to which Article X (1) relates. Article XII a or exhnge of Gains derived in one of the contracting States from the sale or p. 1?76. exchange of capital assets by a resident or corporation or other entity of the other contracting State shall be exempt from taxation in the e el 1734 [62 STAT.
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