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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 theater, 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.         The provisions of paragraphs 1 and 2 of this Article shall not apply to income derived from activities performed by an entertainer or a sportsman, or provided by an enterprise of a Contracting State in a Contracting State if the visit to that Contracting State, or the enterprise providing the activities, as the case may be, is substantially supported by public fund of the other Contracting State , including any local authority or statutory body thereof.

 

 

 

 

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 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
GOVERNMENT SERVICES

 

1.         a)         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 remuneration shall be taxable only in the other Contracting State

                         if the services are rendered in that other 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

                         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 State.

 

3.         The provisions of Articles 15, 16 and 18 shall apply to 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

 

1.         Payments received for the purpose of maintenance, education, or training by a student, apprentice, or trainee 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 shall not be taxed in that State, provided that such payments arise outside that State.

 

2.         Remuneration paid to the student, apprentice, or trainee, as the case may be, for services rendered in the other Contracting State shall not be taxed in that State for a period of 5 years provided that such services are connected with his education, maintenance, or training.

 

Last updated: 08.12.2011