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ARTICLE 16
DIRECTORS' FEES

 

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 or any similar organ of a company which is a resident of the other Contracting State may be taxed in that other State.

 

2.         The remuneration which a person to whom paragraph 1 applies derives from the company in respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 15.

 

 

ARTICLE 17
ARTISTES AND ATHLETES

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 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 activities refer to in paragraph 1 accrues not to the entertainer or an 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.         The provisions of paragraphs 1 and 2 shall not apply:

             (a)        to income derived from activities performed in a Contracting

                          State by entertainers or athletes if the visit to that Contracting

                          State is substantially supported by public funds of the other

                          Contracting State, or by those of any political subdivision,

                          local authority or statutory body thereof,

             (b)        to income derived in a Contracting State by a non-profit

                          organization of the other Contracting State in respect of such

                          activities, provided that such organization is substantially supported

                          by public funds of that other State, or by those of any political

                          sub-division, local authority or statutory body thereof.

 

ARTICLE 18
PENSIONS AND ANNUITIES

1.         Subject to the provisions of paragraph 2 of Article 19, pensions or other similar remuneration paid to a resident of one of the Contracting States from a source in the other Contracting State in consideration of past employment or services in that other Contracting State and any annuity paid to such a resident from such a source may be taxed in that other 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 or money's worth.

 

 

ARTICLE 19
GOVERNMENT SERVICE

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

                         or a local authority thereof to an individual in respect of services

                         rendered to that State or authority shall be taxable in that State.

 

            (b)        However, such remuneration shall be taxable only in the other

                         Contracting State if the services are rendered in that other 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 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 individual is a resident of, and a national

                         of, that other State.

 

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 local authority thereof

 

 

ARTICLE 20
STUDENTS

             Payments which a student, apprentice or business trainee 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 his education or training, receives for the purpose of his maintenance, education or training, shall not be taxed in that first-mentioned State, provided that such payments are made to him from sources outside that State.

 

 

Last updated: 08.12.2011