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.
ARTISTES AND SPORTSMEN
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.
(b) However, such remuneration shall be taxable only in the other Contracting
(i) is a national of that State; or
(ii) did not become a resident of that State solely for the
2. (a) Any pension paid by, or out of funds created by, a Contracting State or
(b) However, such pension shall be taxable only in the other Contracting
(a) studying at a university or other recognized educational institution; or
(b) securing training to qualify him to practice a profession or trade; or
(c) studying or carrying out research as a recipient of a grant, allowance or
(i) remittances from abroad for the purposes of his maintenance,
(ii) the grant, allowance or award; and
(iii) income from personal services rendered in that State provided