Directors fees and 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 Remuneration paid by or out of funds created by a Contracting State, a Land, a political subdivision, a local authority or a local administration there of to any individual in respect of an employment, shall be exempt from tax in the other Contracting State unless the payment is made to a national of that other State who is not also a national of the first-mentioned Contracting State.
2 Notwithstanding the provisions of paragraph 1 the provisions of Articles 14 and 15 shall apply to remuneration in respect of an employment in connection with any trade or business carried on by a Contracting State, Land, a political subdivision, a local authority or a local administration thereof.
3 The provisions of paragraph 1 shall also apply to remuneration paid, in the case of the Federal Republic by the Deutsche Bundesbank, the Deutsche Bundesbahn and the Deutsche Bundespost, and in the case of Thailand by the Bank of Thailand and any other organization of a governmental nature.
1 Pensions and other payments for past employment as well as annuities derived by a resident of a Contracting State may be taxed in the other Contracting State only if such payments are deducted as expenses in determining the profits of an enterprise of that other State or of a permanent establishment situated therein.
2 Notwithstanding the provisions of paragraph 1, pensions and other payments for past employment as well as annuities paid by or out of funds created by a Contracting State, a Land, a political subdivision, local authority or local administration thereof shall be exempt from tax in the other Contracting State.
3 Paragraph 2 shall likewise apply in respect or pensions, annuities and other recurring or not recurring remuneration paid to any individual by a Contracting State, a Land a political subdivision, a local authority or local administration thereof as compensation for an injury or damage sustained as a result of hostilities or political persecution.
An individual, who is or was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that other Contracting State solely for the purpose of teaching at a university, college, school or other educational institution in that other State for a period not exceeding two years shall be exempt from tax in that other Contracting State on his remuneration for such teaching.
1 An individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that other State solely as a student at a recognized university, college, or school in that other Contracting State, or as a business apprentice (including in the Federal Republic a Volontar or a Praktikant), shall be exempt from tax in that other State on (a) all remittances from abroad for the purposes of his maintenance, education or training, and (b) any remuneration for personal services rendered in that other State supplementing the resources available to him for such purposes.
2 An individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that other State for a period not exceeding two years solely for the purpose of study, research or training as a recipient of a grant, allowance or award from a scientific, educational, religious or charitable organization or under a technical assistance program entered into by the Government of a Contracting State shall be exempt from tax in that other State on (a) the amount of such grant, allowance or award, and (b) all remittances from abroad for the purposes of his maintenance, education or training, and (c) any remuneration for personal services rendered in that other State provided such services are in connection with his study, research or training or are incidental thereto.
3 An individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State and who is temporarily present in that other State for a period not exceeding twelve months solely as an employee of, or under contract or arrangement with, the Government or an enterprise of that other State for the purpose of acquiring technical, professional or business experience shall be exempt from tax in that other State on (a) all remittances from abroad for the purposes of his maintenance, education or training, and (b) any remuneration, so far as it is not in excess of 15.000 Deutsche Mark or the equivalent in Thai currency, for personal services rendered in that other State, provided such services are in connection with his studies or training or are incidental thereto.
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