ARTICLE 16
DIRECTORS' FEES AND REMUNERATION OF
TOP-LEVEL MANAGERIAL OFFICIALS 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. Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official in a top-level managerial position of a company which is a resident of the other Contracting State may be taxed in that other State. ARTICLE 17
INCOME EARNED BY ENTERTAINERS AND ATHLETES 1. Notwithstanding the provisions of Article 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as theatre, 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 activitties exercised by an entertainer or an athlete in his capacity as such accrues not to the entertainer or athlete 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 athlete are exercised. 3. Notwithstanding the provisions of Articles 7 and 14, where the activities mentioned in paragraph 1 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 State unless the enterprise is substantially supported by public funds of the other Contracting State, including any political subdivision or local authority in connection with the provision of such activities. 4. The provisions of paragraphs 1 and 2 of this Article shall not apply to remuneration or profits, salaries, wages and similar 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 Contrancting State, including any political subdivision or local authority thereof. ARTICLE 18
GOVERNMENT SERVICE 1. a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision 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 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 political subdivision or a local authority thereof to an individual respect of services rendered to that State or subdivision or authority shall 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 other State. 3. The provisions of Article 15,16 and 21 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof. ARTICLE 19
STUDENTS AND TRAINEES 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, college or school 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 award from a governmental, religious, charitable, scientific, literary or educational organization ; shall be exempt from tax in the first-mentioned Contracting State on ; (i) remittance from abroad for the purpose of his maintenance, education, study, research or training; (ii) the grant, allowance or award ; and (iii) income from personal services rendered in that State, provided the income does not exceed 15,000 Swedish Kronor or its equivalent in Thai currency for any calendar year or such other amounts as the competent authorities of the Contracting States may from time to time agree upon. ARTICLE 20
PROFESSORS, 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 due 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 any remuneration for such teaching or research. 2. This Article shall only apply to income from research if such research is undertaken by the individual in the public interest and not primarily for the benefit of some other private person or persons. | 
