ARTICLE 16
Artistes and Athletes

1.         Notwithstanding the provisions of Article 14, income derived by public entertainers, such as theatre, motion picture, radio or television artistes, and musicians, and by athletes, from their personal activities as such may be taxed in the Contracting State in which these activities are performed.

2.         The provisions of paragraph 1 shall not apply to remuneration or profits, salaries, wages and similar income derived from activities performed in a Contracting State by public entertainers if the visit to that Contracting State is substantially supported by public funds of the other Contracting State, including any political subdivision or local authority thereof.

3.         Notwithstanding the provisions of Article 7, where the activities mentioned in paragraph 1 are provided 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 substantially supported by public funds of the other Contracting State, including any political subdivision or local authority thereof, in connection with the provision of such activities.

ARTICLE 17
Pensions

1.         Subject to the provisions of Article 18, pensions or other remuneration for past employment arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in the first - mentioned State.

2.         Pensions or other remuneration for past employment shall be deemed to arise in a Contracting State if the payer is that State itself, a political subdivision or local authority or a resident of that State. Where, however, the person paying such income, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment, and such income is borne by the permanent establishment, then the income shall be deemed to arise in the Contracting State in which the permanent establishment is situated.

ARTICLE 18
Government service

1.         (a)        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 local authority thereof 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 recipient is a resident of that State who:

                         (1)        is a national of that  State; or

                         (2)        did not become a resident of that State solely for the

                                      purpose of performing 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 local authority thereof shall be taxable only in

                         that State.

            (b)        However, such pension shall be taxable only in the other

                         Contracting State if the recipient is a national of and a

                         resident of that State.

3.         The provisions of Articles 14, 15 and 17 shall apply to remuneration and pensions in respect of services rendered in connection with any business carried on by one of the Contracting State or a political subdivision or a local authority thereof.

ARTICLE 19
Students

A resident of a Contracting State, who temporarily visits the other Contracting State solely

            (a)        as a Student at a university, college or school in that other

                         State,

            (b)        as a business or technical apprentice, or

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

                         purpose of study or research from a religious, charitable,

                         scientific or educational organization,shall not be taxed in

                         that other State in respect of payments received from

                        sources outside that State for the purpose of his

                        maintenance, education or training, or in respect of

                        scholarship grant. The same shall apply to any reasonable

                        amount representing remuneration for services rendered in

                        that other State, provided that such services are in connection

                        with his studies or training or are necessary for the purpose

                        of his maintenance However, this clause shall not apply to

                        such cases in which the studies or practices have a

                        secondary character in respect of services rendered that are

                        producing the said remuneration.

ARTICLE 20
Professors, teachers and researchers

A resident of Contracting State who, at the invitation of a university, college or other establishment for higher education or scientific research in the other Contracting State, visits that other State solely for the purpose of teaching or scientific research at such institution for a period not exceeding two years shall not be taxed in that other State on his remuneration for such teaching or research.

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