MenuClose

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 or any similar organ 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 the sportsman are exercised.

 

3.             Notwithstanding the provisions of paragraphs 1 and 2, the income mentioned in this Article shall be exempt from tax in the Contracting State in which the activity of the entertainer or sportsman is exercised provided that this activity is supported wholly by public funds of either Contracting State or a local authority thereof, or the activity is exercised within the framework of  cultural   or sport cooperation agreement   between  the Contracting States.

 

 

ARTICLE 18
PENSIONS

1.             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.

 

2.             Notwithstanding the provisions  of paragraph 1, pensions paid and other similar payments made under a public scheme which is part of the social security system of a Contracting State 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 local

                                authority thereof, to an individual in respect of services

                                rendered to that State or authority shall be taxable only in

                                that State.

                 b)            However,  such  salaries,  wages  and  other similar

                                 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 local authority thereof to an

                                individual in respect of services rendered to that State or

                                local 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 Articles 15, 18, 17 and 18 shall apply to salaries, wages and other similar remuneration, and pensions,  in respect of services rendered in connection with a business carried on by a Contracting State or a local authority thereof.

 

 

ARTICLE 20
STUDENTS  AND APPRENTICES

1.             Payments which a student or apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources  outside that State.

 

2.             In respect of grants, scholarships and remuneration from employment not covered by paragraph 1, a student or apprentice referred  to in paragraph 1 shall, in addition be entitled during such education or training  to the same  exemptions, relieves or reductions in respect of taxes available to resident students or apprentices of the Contracting State which he is visiting.

 

 

Last updated: 08.12.2011