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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.

 

 

Last updated: 08.12.2011