ARTICLE 16
Directors’ Fees

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

2.         The provisions of paragraph 1 shall likewise apply to payments received by an official of a company in a top level managerial position who in fact carries out functions which are of a similar nature as those performed by a person as referred to in that paragraph 1.

ARTICLE 17
Artistes and Athletes

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 an athlete, including a boxer or a wrestler, from his personal activities as such are 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 an athlete in his capacity as such accrues not to the entertainer or athlete 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 athlete are exercised.

3.             Notwithstanding the provisions of Article 7, where the activities mentioned in paragraphs 1 and 2 of this Article are providing in a contracting State by an enterprise of the other Contracting State the profits derived from providing these activities by such an enterprise may be taxed in the first-mentioned Contracting State unless the enterprise is supported from the public funds of the other Contracting State, including any political sub-division, local authority or statutory body thereof, in connection with the provision of such activities.

4.         The provision of paragraph 1 shall not apply in the case of cultural and sports programmes sponsored by or on behalf of any of the Contracting States.

ARTICLE 18
Pensions

1.             Pensions, annuities and other similar remuneration in Contracting State may be taxed in that State.

2.             Pensions, annuities and other similar remuneration shall be deemed to arise in a Contracting State when the payer is that State itself, a political sub-division, a local authority or a resident of that State.

3.         The term “pensions, annuities and other similar remuneration”, as used in this Article, means periodic payments made after retirement in consideration of past employment or by way of compensation for injuries received in connection with past employment.

ARTICLE 19
Governmental Functions

1.         (a)             Remuneration, other than a pension, paid by a

                              Contracting State or a  political sub-division or a local

                              authority thereof to an individual in respect of services

                              rendered to that State or sub-division 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 the State who:

                             (i)             is a national of that State; or

                            (ii)             did not become resident of that State solely for

                                              the purpose of rendering the services.

2.         The provisions of paragraph 1 shall not apply to remuneration in respect of services rendered in connection with any trade or business carried on by one of the Contracting States or a political sub-division or a local authority thereof.

ARTICLE 20
Teachers, Students and Trainees

1.         A resident of one of the Contracting States who is temporarily present in the other Contracting State solely--

            (a)        as a student at a recognised University, College or School in

                         the other Contracting State;

            (b)        as an apprentice to acquire technical, professional or

                         business experience from a person other than his employer

                         or an organisation referred to in (c) below;

            (c)        as the recipient of a grant, allowance or award for the primary

                         purpose of study or research from religious charitable,

                         scientific or educational organisation of the former State; or

            (d)        as a trainee under arrangements with the Government of the

                         other Contracting State or any agency or instrumentality

                         thereof for the purpose of training, study or orientation, shall

                         not be taxed in the other Contracting State in respect of

                         remittances from abroad for the purpose of his maintenance,

                         education or training or in respect of a scholarship grant.

2.         A resident of a Contracting State who visits the other Contracting State for a period not exceeding two years, for the purpose of teaching or research at a research institute, college, school or other educational establishment in that other Contracting State shall be exempt from tax in both the Contracting States in respect of any payments which he receives for such activity.

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