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 or television artists, and musicians, and by atheletes, from their personal activities as such may be taxed in the Contracting State in which these activities are exercised unless the visit to that State is substantially directly or indirectly, by public funds of the other Contracting State. 2. Notwithstanding anything contained in this Convention where the services mentioned in paragraph 1 are provided in a Contracting State by an enterprise of the other Contracting State, the profits derived from providing those services by such enterprise may be taxed in the first-mentioned State unless the enterprise in substantially supported, directly or indirectly, by public funds of the other Contracting State in connection with the provision of such services. 3. For the purpose of this Article, the term "public funds of a Contracting State" shall include public funds created by an administrative or a local authority thereof. ARTICLE 18 Pensions 1. Subject to the provisions of paragraph 1 of Article 19, pensions and other similar remuneration paid to resident of a Contracting State in consideration of part employment shall be taxable only in that State. 2. Notwithstanding the provisions of paragraph 1 pensions and other similar remuneration derived by a resident of a Contracting State may be taxed in the other Contracting State if such payments are borne by an enterprise of that other State or by a permanent establishment situated therein. ARTICLE 19 Governmental functions 1. Remuneration, including pensions, paid by, or out of funds created by, a Contracting State or an administrative 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 functions of a governmental nature may be taxed in that States. 2. The provisions of Article 15,16 and 18 shall apply to remuneration or pensions in respect of services rendered in connection with any trade or business carried on by one of the Contracting State or an administrative or a local authority thereof. ARTICLE 20 Professors and Teachers A professor or teacher who makes a temporary visit to a Contracting State for a period not exceeding two years for the purpose of teaching or conducting research at a university, college, school or other educational institution, owned by the Government or nonprofit organizations, and who is, or immediately before such visit was, a resident of the other Contracting State shall be exempt from tax in the first-mentioned Contracting State in respect of remuneration for such teaching or research. |