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 of the supervisory board of a company which is a resident of the other Contracting State may be taxed in that other State.

2.         Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official in a top level managerial position of a company which is a resident of the other Contracting State may be taxed in that other State.

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 artistes 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 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, 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 of this Article shall not apply to remuneration or profits, salaries, wages and other similar income derived from activities performed in a Contracting State by an entertainer or an athlete if the visit to that Contracting State is substantially supported by public funds of the other Contracting State, including any local authority or statutory body thereof, or if the activity is exercised under a cultural agreement or arrangement between the Contracting States.

4.         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 local authority or statutory body thereof, in connection with the provisions of such activities, or unless the activities are exercised under a cultural agreement or arrangement between the Contracting States.

ARTICLE 18
PENSIONS

            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.

ARTICLE 19
GOVERNMENTAL FUNCTION

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

                         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 rendering the services.

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

                         State or a political subdivision or a localauthority thereof to

                         an individual in respect of services rendered to that State or

                         subdivision 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 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

            An  individual who, immediately before visiting a Contracting State, was a resident of the other Contracting State and whose visit to the first mentioned Contracting State is solely for the purpose of:

            (a)        studying at a university or other recognized educational

                         institution; or

            (b)        securing training to qualify him to practice a profession or

                         trade; or

            (c)        studying or carrying out research as a recipient of a grant, 

                        allowance or award from a governmental, religious,

                        charitable, scientific, literary or educational organization; shall

                        be exempt from  tax in the first mentioned State on:

                       (i).        remittances from abroad of the purposes of his

                                    maintenance, education, study, research or training;

                       (ii).       the grant, allowance or award; and

                       (iii)       income from personal services rendered in that State

                                   provided the income constitutes earnings reasonable

                                   necessary for his maintenance and education.

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