1 Subject to the provisions of Articles 19 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.
2 Notwithstanding the provisions of paragraph (1) of this Article, remuneration derived by a resident of a Contracting state in respect of an employment in the other Contracting State shall be taxable only in the first-mentioned State if:
(a) the recipient is present in the other State for a period or
periods not exceeding in the aggregate 183 days in the fiscal
year concerned; and
(b) the remuneration is paid by, or on behalf of, an employer
who is not a resident of the other State; and
(c) the remuneration is not borne by a permanent
establishment or a fixed base which the employer has in the
3 Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment exercised aboard a ship or aircraft in international traffic may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.
Directors' fees and 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.
1 Notwithstanding the provisions of Articles 15 and 16, 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 those activities are exercised.
2 Where income in respect of personal activities as such of an entertainer or athlete accrues not to that entertainer or athlete himself but to another person that income may, notwithstanding the provisions of Articles 8, 15 and 16, 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 and paragraph (4) of Article 5 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.
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 servicesof a governmental
nature 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 other Contracting
(i) is a national of that State; or
(ii) did not become a resident of that State solely for
the purpose of performing the services.
2 (a) Any pension paid by a Contracting State or a political
subdivision or a local authority thereof to any individual in
respect of services of a governmental nature 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 16 and 17 shall apply to remuneration in respect of services rendered in connection with any business carried on by one of the Contracting State or a political subdivision or local authority thereof.
1 An individual who, immediately before visiting a Contracting State, was a resident of the other Contracting state and whose visit to the first-mentioned Contracting State is solely for the purpose of:
(a) studying at a university or other recognized educational
(b) securing training to qualify him to practise a profession or
(c) studying or carrying out research as a recipient of a grant,
allowance or award from a governmental, religious,
charitable, scientific, literary or educational organization;
shall be exempt from tax in the first-mentioned State on:
(i) remittances from abroad for the purposes of his
maintenance, education, study, research or
(ii) the grant, allowance or award; and
(iii) income from personal services rendered in that State
(other than services rendered by an articled clerk,
or other individual under going training, to the person
or partnership to whom he is articled or who is
providing the training) provided the income
constitutes earnings reasonably necessary for his
maintenance and education.
2 In no event shall an individual have the benefit of the provisions of paragraph (1) (iii) of this Article for more than five years.