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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 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
ARTISTES AND SPORTSPERSONS

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 sportsperson, 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 sportsperson in his capacity as such accrues not to the entertainer or sportsperson 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 sportsperson are exercised.            

3.             Notwithstanding the provisions of paragraphs 1 and 2 of this Article, however, income derived from personal activities by a resident of a Contracting State in his capacity of a performer or sportsman shall be taxable only in that Contracting State if the activities have been performed in the other Contracting State within the scope of cultural or sports exchange programme approved by both 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
GOVERNMENT SERVICE


1.             a)           Salaries, wages and other similar remuneration, other than
                               a pension, paid by a Contracting State or a political subdivision
                               or a local authority 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 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 or a political subdivision or a local authority 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 S?tate.            

3.             The provisions of Articles 15, 16, 17 and 18 shall apply to salaries, wages and other similar remuneration and to pen?sions 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.            

 

Article 20
PROFESSORS, TEACHERS AND RESEARCHERS


1.             An individual who is or was immediately before visiting a Contracting State a resident of 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 the first-mentioned Contracting State, visits that first-mentioned Contracting State for a period not exceeding two years solely for the purpose of teaching or researching or both at such educational institution shall be exempt from tax in the first-mentioned Contracting State on any remuneration for such teaching or research.            

2.             The provisions of paragraph 1 shall not apply to income from researching if such research is undertaken by the individual primarily for the private benefit of a specific person or persons.            

 

Last updated: 08.12.2011