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. Income derived by an entertainer or a sportsman from activities exercised in a Contracting State shall be exempt from tax in that State, if the visit to that State is supported wholly or mainly by public funds of the other Contracting State, a political subdivision or a local authority thereof.
Article 18
PENSIONS
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.
Article 19
GOVERNMENT SERVICE
1. a) Salaries, wages and other similar remuneration, other than
a pension, paid by a Contracting State or a political subdivision
or a local authority thereof to any individual in respect of
services rendered to that State or subdivision or authority
shall be taxable only in that State.
b) However, such salaries, wages and other 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 political subdivision or a local authority thereof to
any individual in respect of services rendered to that State or
subdivision 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 other State.
3. The provisions of Article 15, 16, 17 and 18 of this Agreement shall apply to salaries, wages and other similar remuneration and to pensions paid in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.
Article 20
PROFESSORS, TEACHERS AND RESEARCHERS
1. An individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State, and who, at the invitation of any university, college, school or other similar educational institution which is recognised by the competent authority in the first-mentioned Contracting State, visits that first-mentioned Contracting State for a period not exceeding two (2) years solely for the purpose of teaching or research or both at such educational institution shall be exempt from tax in that other Contracting State on any remuneration for such teaching or research.
2. The provisions of paragraph 1 shall not apply to income from research if such research is undertaken by the individual primarily for the private benefit of a specific person or persons.
