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 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 Sportsmen 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 sportsman, 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 sportsman in his capacity as such accrues not to the entertainer or sportsman 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 sportsman are exercised. 3. The provisions of paragraphs 1 and 2 of this Article shall not apply to income derived from activities performed in a Contracting State if the visit to that Contracting State is substantially supported by public funds of the other Contracting State or a political subdivision or a local authority thereof. ARTICLE 18
Pensions and Annuities 1. (a) Pensions (and another similar remunerations) arising in a Contracting State and paid to a resident of the other Contracting State; (b) Any payments, whether periodic or non-periodic, made under the social security legislation of a Contracting State or under any public scheme organized by a Contracting State for social welfare purposes; (c) Any annuity arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in both Contracting States. 2. The term "annuities" as used in this Article means stated sums 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 (other than services rendered). 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 State. 3. The provisions of Articles 15, 16 and 18 shall apply to salaries, wages and other similar remuneration, and to pensions 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
Students An individual who is or was immediately before visiting a Contracting State 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 practise 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 not be taxed in the first·mentioned State on: (i) remittances from abroad for 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 for a period not exceeding 5 years provided the income constitutes earnings reasonably necessary for his maintenance and education. | 
