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 or any other similar organ of a company which is a resident of the other Contracting State may be taxed in that other State. ARTICLE 17
Artists 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 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 Article 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or athlete are exercised. 3. Notwithstanding the provisions of Article 7, where the activities mentioned in paragraph 1 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. 4. The provisions of paragraphs 1, 2 and 3 shall not apply to remuneration or profits, salaries, wages and similar income derived from activities performed in a Contracting State if such activities are substantially supported by the Government or from public funds of the other Contracting State, including any local authority thereof. ARTICLE 18
Pensions 1. 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. 2. Notwithstanding the provisions of paragraph 1, pensions and other similar remuneration derived by a resident of a Contracting State may be taxed in the other Contracting State if such payments are borne by an enterprise of that State or by a permanent establishment situated therein. 3. Notwithstanding the provisions of paragraphs 1 and 2, and subject to the provisions of paragraph 2 of Article 19, pensions paid and other payments made under the social security legislation of a Contracting State may be taxed according to the law of each Contracting State. ARTICLE 19
Government Service 1. a) Remuneration, other than a pension, paid by a Contracting State or a statutory body or a local authority thereof to an individual in respect of services rendered to that State or body or authority shall be taxable only in that State. b) However, such remuneration shall be taxable only in the Contracting State of which the individual is a resident if the services are rendered in that State and the individual: (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 statutory body or a local authority thereof to an individual in respect of services rendered to that State or body 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 Article 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 statutory body or a local authority thereof. ARTICLE 20
Students and trainees 1. An individual who, immediately before visiting a Contracting State, is or 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, college or school or other similar educational institution which is recognised by the competent authority of that first-mentioned State, 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 for the purpose of his maintenance, education, study, research or training; and (ii) the grant, allowance or award. 2. An individual who, immediately before visiting a Contracting State, is or was a resident of the other Contracting State and who is present in the first-mentioned State for a period or periods not exceeding in the aggregate 183 days in the calendar year concerned solely for the purpose of: a) studying at a university, college or school or other similar educational institution which is recognised by the competent authority of that first-mentioned State, or b) securing training to qualify him to practise a profession or trade, or c) studying or carrying out research as a recipient of a grant, allowance or award from a government, religious, charitable, scientific, literary or educational organization; shall be exempt from tax in that first-mentioned State in respect of income from personal services rendered in that State provided that the income constitutes earnings necessary for his maintenance and education. If he is present in that first-mentioned State for a period or periods aggregating more than 183 days in the calendar year concerned, he shall be entitled to the same exemptions, reliefs or reductions in respect of taxes as are granted to residents of that State. | 
