ARTICLE 16
Dependent Personal Services

1.         Subject to the provisions of Articles 17, 19, 20 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, remuneration derived by a resident of a Contracting State in respect of an employment exercised 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 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 other State.

3.         Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State shall be taxable only in that State.

ARTICLE 17
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.

ARTICLE 18
Artistes and Athletes

1.         Notwithstanding the provisions of Articles 15 and 16, income derived by public entertainer, 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 these activities are performed.

2.         Where income in respect of personal activities 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, 15 and 16, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised.

3.         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 enterprise is substantially supported from the public funds of the other Contracting State, including any territorial administrative unit, or local authority, or statutory body thereof, in connection with the provisions 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 public entertainers or athletes if the visit to that Contracting State is substantially supported by public funds of the other Contracting State, including any territorial administrative unit, or local authority, or statutory body thereof.

ARTICLE 19
Pensions and Annuities

1.         Subject to the provisions of paragraph 2 of Article 20, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment, and any annuity paid to such a resident shall be taxable only in that State.

2.         The term "annuity" means a stated sum, payable periodically, at stated times, during life or during a specified or ascertainable period of time, under an obligation to make the payments in return for adequate and full consideration in money's worth.

ARTICLE 20
Governmental Functions

1.         (a)        Remuneration, other than a pension, paid by a Contracting

                         State, or a territorial administrative unit, or a local authority 

                         thereof to any individual, in respect of services rendered to

                         that State, or unit, or local 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 preforming the services.

2.         (a)        Any pension paid by, or out of funds created by a Contracting

                         State, a territorial administrative unit, or a local authority

                         thereof to any individual in respect of services rendered to

                         that State, or a territorial administrative unit, or a 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 individual is a national of, and a

                         resident of that State.

            The provisions of Articles 16, 17 and 19 shall apply to remuneration and pensions in respect of services rendered in connection with any business carried on by a Contracting State, or a territorial administrative unit, or a local authority thereof.

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