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.
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. Income derived by a resident of a Contracting State from activities exercised in a Contracting State as envisaged in paragraphs 1 and 2 of this Article, shall be exempt from tax in that State if the visit to that State is supported wholly or mainly by public funds of the other Contracting State including any local authority or statutory body thereof.
Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State.
1. (a) Remuneration, other than a pension, paid by a Contracting State or a political
(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
(i) is a national of that State; or
(ii) did not become a resident of that State solely for the purpose of
2. a) any pension paid by, or out of funds created by, a Contracting State or a
politicalsubdivision or a local authority thereof to an individual in respect of
services rendered to that State or authority shall be taxable only in that State.
(b) however, such pension shall be taxable only in the other Contracting State if the
3. The provisions of Articles 15, 16 and 18 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.
Payments which a student or business apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of this education or training received for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State.