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ARTICLE 16
DIRECTORS' FEES

 

           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.

 

 

ARTICLE 17
ENTERTAINERS AND SPORTSMEN

1.        Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer such as a theatre, 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.        Notwithstanding the provisions of paragraphs 1 and 2, income derived from activities referred to in paragraph 1 shall be exempt from tax in the Contracting State in which the activities are exercised if the visit to that State is wholly or substantially supported by funds of either Contracting State, a local authority or public institution thereof.

 

 

ARTICLE 18
PENSIONS

1.        Subject to the provisions of paragraph 2 of Article 19, pensions and other similar payments arising in a Contracting State and paid in consideration of past employment to a resident of the other Contracting State, shall be taxable only in that other State.

 

2.        Notwithstanding the provisions of paragraph 1, pensions paid and other payments made under a public scheme which is part of the social security system of a Contracting State or a political subdivision or a local authority thereof shall be taxable only in that State.

 

 

ARTICLE 19
GOVERNMENT SERVICE

1.        (a)         Salaries, wages, and other similar remuneration, other than

                         a pension, paid by a Contracting State, local authority,

                         political subdivision or statutory body thereof to an individual

                         in respect of services rendered to that State, authority,

                         subdivision or body shall be taxable only in that State.

           (b)        However, such salaries, wages and other similar

                        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, local authority, political subdivision, or statutory body

                        thereof to an individual in respect of services rendered to that

                        State, authority, subdivision  or body 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 resident of, and a

                        national of, that State.

 

3.        The provisions of Articles 15, 16, 17 and 18 shall apply to salaries, wages and other similar remuneration, and to pensions, in respect of services rendered in connection with a business carried on by a Contracting State, local authority, political subdivision or statutory body thereof.

 

 

ARTICLE 20
PROFESSORS, TEACHERS AND RESEARCHERS

1.        Notwithstanding the provisions of Article 15, a professor, teacher or researcher who makes a temporary visit to one of the Contracting States for a period not exceeding two years for the purpose of teaching or carrying out research at a university, college, school or other educational institution in that State and who is, or immediately before such visit was, a resident of the other Contracting State shall, in respect of remuneration for such teaching or research, be exempt from tax in the first·mentioned State, provided that such remuneration is derived by him from outside that State.

 

2.        The provisions of this Article shall not apply to income from research if such research is undertaken not in the public interest but wholly or mainly for the private benefit of a specific person or persons.

 

 

Last updated: 08.12.2011