ARTICLE 16 DIRECTORS' FEES 1. Directors' fees and other 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. 2. The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 15. ARTICLE 17 ARTISTES AND ATHLETES 1. Notwithstanding the provisions of Article 15, income derived by a resident of a Contracting State as an entertainer, such as a theater, motion picture, radio or television artiste, or a musician, or as an athlete, 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 an athlete in his capacity as such accrues not to that entertainer or athlete himself but to another person, that income may, notwithstanding the provisions of Articles 7 and 15, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply to income derived from activities performed in a Contracting State by an entertainer or an athlete if the visit to that Contracting State is substantially supported by public funds of the other Contracting State, including those of any political subdivision, local authority or statutory body thereof, nor to in income derived by a non-profit organization in respect of such activities provided no part of its income is payable to, or is otherwise available for the personal benefit of its proprietors, members of shareholders and the organization is certified as qualifying under this provision by the competent authority of the other State. 4. Notwithstanding the provisions of Article 7, where the activities mentioned in paragraph 1 of this Article 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 from the public funds of the other Contracting State, including any political subdivision, local authority or statutory body thereof, in connection with the provisions of such activities, or unless the enterprise is a non-profit organization referred to in paragraph ARTICLE 18 PENSIONS 1. Subject to the provisions of paragraph 1 of Article 19, pensions and other similar remuneration for past employment arising in a Contracting State shall be taxable only in that State. 2. The term "pensions" as used in this Article means periodic payments made in consideration for past services rendered. ARTICLE 19 GOVERNMENTAL FUNCTIONS 1. Remuneration including pension paid by or out of public funds of a Contracting State or a political subdivision or local authority or statutory body thereof to: (a) national of that Contracting State; (b) an individual who is not national of the other Contracting State and goes to the other State solely for the purpose of being engaged by the first-mentioned State,for services rendered to that State in the discharge of functions of a governmental nature shall be exempt from tax in the other State. 2. The provisions of paragraph 1 shall not apply to remuneration including pension paid in respect of services rendered in connection with any trade or business carried on by a Contracting State or a political subdivision or local authority or statutory body thereof. ARTICLE 20 TEACHERS AND RESEARCHERS 1. An individual who is a resident of a Contracting State immediately before making a visit to the other Contracting State, and who, at the invitation of any university, college, school or other similar educational institution, which is recognized by the competent authority in that other Contracting State, visits that other Contracting State for a period not exceeding two 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 his remuneration for such teaching or research. 2. This Article shall not apply to income from research if such research in taken under not in the general interest but primarily for the private benefit of a specific person or persons. |