Article 16

DIRECTORS' FEES

            Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as, or on behalf of, a member of the board of directors of a company which is a resident of the other Contracting State may be taxed in that other State.

Article 17

ARTISTES AND SPORTSMEN

1.         Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsman, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State.

2.         Where income in respect of personal activities exercised by an entertainer or a sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised.

3.         The provisions of paragraphs 1 and 2 of this Article shall not apply to income derived from activities performed by an entertainer or a sportsman, or provided by an enterprise of a Contracting State in a Contracting State if the visit to that Contracting State, or the enterprise providing the activities, as the case may be, is substantially supported by public fund of the other Contracting State, including any local authority or statutory body thereof.

Article 18

PENSIONS

1.         Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State.

2.         Notwithstanding the provisions of paragraph 1, pensions and other payments made under a public scheme which is part of the social security system of a Contracting State, political subdivisions, local authorities or local governments thereof shall be taxable only in that State.

Article 19

GOVERNMENTAL FUNCTION

1.         (a)        Remuneration, other than a pension, paid by a Contracting State or a local
                         authority thereof to an individual in respect of services rendered to that State
                         or authority shall be taxable only in that State.

            (b)        However, such remuneration shall be taxable only in the other Contracting
                         State if the services are rendered in that State and the individual is a resident
                         of that State who :

                         (i)         is a national of that State; or

                         (ii)        did not become a resident of that State solely for the                                      
                                      purpose of rendering the services.

2.         (a)        Any pension paid by, or out of funds created by, a Contracting State or
                         a local authority thereof to an individual in respect of services rendered
                         to that State or authority shall be taxable only in that State.

             (b)        However, such pension shall be taxable only in the other Contracting
                           State if the individual is a resident of, and a national of, that State.

3.         The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a local authority thereof.

Article 20

STUDENTS

            An individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State and whose visit to the first-mentioned Contracting State is solely for the purpose of:

           (a)        studying at a university or other recognized educational institution; or

           (b)        securing training to qualify him to practice a profession or trade; or

           (c)        studying or carrying out research as a recipient of a grant, allowance or
                        award from a governmental, religious, charitable, scientific, literary or
                        educational organisation;
                         shall be exempt from tax in the first-mentioned State on :

                       (i)         remittances from abroad for the purposes of his maintenance,
                                    education, study, research or training;

                       (ii)        the grant, allowance or award; and

                       (iii)       income from personal services rendered in that State provided
                                    the income constitutes earnings reasonably necessary for his
                                    maintenance and education.

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