ARTICLE 16
Directors fees Directors fees and similar payments derived by a resident of a Contracting State in his capacity as 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 athletes 1. Notwithstanding the provisions of Articles 14 and 15, income derived by public entertainers, such as theatre, motion picture, radio and television, artistes and musicians, and by athletes, from their personal activities as such may be taxed in the Contracting State in which these activities exercised. 2. Where income in respect of the personal activities as such of a public entertainer accrues not to that entertainer 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 are exercised. 3. The provisions of paragraphs 1 and 2 shall not apply in the case of cultural and sport programmes sponsored by or on behalf of each of the Contracting States. ARTICLE 18
Governmental Functions Remuneration, including pensions, paid by or out of funds created by, a Contracting State of a political subdivision or a local authority thereof to any individual in respect of services rendered to that State or subdivision or local authority thereof in the discharge of function of a governmental nature may be taxed in that State. ARTICLE 19
Students An individual who, immediately before visiting a Contracting State, was 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 recognised educational institution; or b) securing training to qualify him to practise 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 organization; shall be exempt from tax in the first-mentioned State on : remittances from abroad for the purpose of his maintenance, education, study, research or training; the grant, allowance, or award; and income from personal services rendered in that State (other than services rendered by an articled clerk, or other individual undergoing training, to the person or partnership to whom he is articled or who providing the training) provided the income constitutes earnings reasonably necessary for his maintenance and education. ARTICLE 20
Professors, teachers and research workers 1 An individual who, at the invitation of a university, college, school or other similar recognised educational institution in one of the Contracting States, visits that Contracting State, solely for the purpose of teaching or research at such educational institution and who is, or was immediately before that visit, a resident or the other Contracting State shall be exempt from tax in the first-mentioned Contracting State on any remuneration for such teaching or research for a period not exceeding two years from the date of his arrival in that State. 2. The provisions of paragraph 1 shall not apply to income from research if such research is undertaken not in the public interest but primarily for the private benefit of a specific person or persons. | 
