ARTICLE 16
ARTISTES AND ATHLETES 1. Notwithstanding the provisions of Article 14, income derived by public entertainers (such as stage, motion picture, radio or television artistes and musicians) or athletes, from their personal activities as such may be taxed in the Contracting State in which these activities are exercised. 2. Where the personal activities referred to 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 Contracting State. 3. The provisions of paragraphs 1 and 2 shall not apply to remuneration or profits derived from activities exercised in a Contracting State if the visit to that Contracting State is directly or indirectly supported wholly or substantially from the public funds of the other Contracting State, a political sub-division, a local authority or statutory body thereof. ARTICLE 17
PENSIONS AND ANNUITIES 1. Subject to the provisions of Article 18, any pension or other remuneration for past employment or any annuity arising in a Contracting State and paid to resident of the other Contracting State may be taxed in the first-mentioned Contracting State. 2. Pensions or other remuneration for past employment shall be deemed to arise in a Contracting State if the payer is that Contracting State itself, a political subdivision or local authority or a resident of that Contracting State. Where, however, the person paying such income, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment, and such income is borne by the permanent establishment, then the income shall be deemed to arise in the Contracting State in which the permanent establishment is situated. 3. The term "annuity" includes 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 or money's worth. ARTICLE 18
GOVERNMENTAL FUNCTIONS 1 (a) Remuneration, other than a pension, paid by a Contracting State or a political sub-division or a local authority thereof to any individual in respect of services rendered to that Contracting State or political sub-division or local authority thereof shall be taxable only in that Contracting State. (b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that Contracting State and the recipient is a resident of that other Contracting State who: (i) is a national of that Contracting State; or (ii) did not become a resident of that Contracting State solely for the purpose of performing the services. 2. Any pension paid by, or out of funds created by, a Contracting State or a political sub-division or a local authority thereof to any individual in respect of services rendered to that Contracting State or political sub-division or authority thereof may be taxed in the other Contracting State. 3. The provisions of Article 14,15 and 17 shall apply to remuneration or pensions in respect of services rendered in connection with any trade or business carried on by a Contracting State or a political sub-division or a local authority thereof. ARTICLE 19
STUDENTS AND APPRENTICE An individual who is a resident of a Contracting State immediately before making a visit to the other Contracting State and is temporarily present in that other Contracting State solely (a) as a student at a recognised university, college or school; (b) as a recipient of grant, allowance or award for the primary purpose of study or research from a government, religious, charitable, scientific, literary or educational organisation; or (c) as a business or technical apprentice, shall be exempt from tax in that other Contracting State in respect of (i) remittances from abroad for the purposes of this maintenance, education, study, research or training, (ii) the grant, allowance or award, and (iii) remuneration for personal services in that other Contracting State not exceeding 3,600 Malaysian ringgit or 28,800 Thai baht during any calendar year or such other amounts as the competent authorities of the Contracting States may from time to time agree upon, provided that such services are in connection with his study, research or training or are necessary for the purpose of his maintenance. ARTICLE 20
PROFESSORS, 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, which is recognised by the competent 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. | 
