Where a resident of the Contracting State derives income from employment, such as salaries, wages and other similar remuneration, such income from employment shall be levied based on the proportion of the days of his or her actual presence in the territory of the ROC to the whole period of employment. However, in the case that the ratio of the contribution attributed to the services performed within the territory of the ROC is higher than the aforesaid proportion, this latter ratio shall be used as basis for the calculation of the income from employment from ROC source.