ARTICLE 16
TEACHERS AND RESEARCHERS 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 or scientific research institution visits that other State for a period not exceeding three years solely for the purpose of teaching or researching or both at such educational institution or scientific research institution shall be exempt from tax for a period not exceeding three years in that other State. ARTICLE 17
STUDENTS AND TRAINEES 1. A student or business apprentice who, immediately before visiting a Contracting State is or was a resident of the other Contracting State and who is present in the first-mentioned Contracting State for the purpose of his education or training shall be exempt from tax in that first-mentioned Contracting State on : (a) payments made to him by persons residing outside that first-mentioned Contracting State for the purpose of his maintenance, education or training; (b) remuneration from employment in that first-mentioned Contracting State, provided that such employment being a full time employment, lasts not more than 183 days in the year of assessment. 2. An individual who, immediately before visiting a Contracting State is or was resident of the other Contracting State and who is temporarily present in the first-mentioned State primarily for the purpose of studying, researching or training as a recipient of a grant, allowance or award from a scientific, educational, religious or charitable organization or under a technical assistance program entered into by the Government of a Contracting State shall, from the date of his arrival in the first-mentioned State in connection with that visit, be exempt from tax in the State for a period not exceeding the period of the grant. ARTICLE 18
ARTISTES AND SPORTSMEN 1. Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as a public 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 remuneration or profits, salaries, wages and other similar income derived from activities performed in a Contracting State by an entertainer or a sportsman if the visit to that Contracting State is substantially supported by public funds of the other Contracting State, including any political subdivisions, local authorities, local governments or statutory body thereof. 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 visit to the other Contracting State of the enterprise is substantially supported from the public funds of the other Contracting State, including any political subdivisions, local authorities, local governments or statutory body thereof, in connection with the provisions of such activities. ARTICLE 19
DIRECTORS FEES 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. In determining a taxable income of a director, there shall be allowed such deduction as expenses, allowances, and other expenses as provided under the domestic laws of that Contracting State. ARTICLE 20
PENSIONS AND ANNUITIES 1. Subject to the provisions of paragraph 2 of Article 21, pensions, and annuities 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 payments made under a public scheme which is part of the social security system of a Contracting State, political subdivisions, local authorities or local governments thereof shall be taxable only in that State. | 
