ARTICLE 16
DIRECTORS' FEES

            Directors' fees and similar payments derived by a resident of one of the Contracting States in the the capacity of the resident 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
ENTERTAINERS

1.         Notwithstanding the provisions of Articles 14 and 15, income derived by entertainers (such as theatrical motion picture, radio or television artistes, musicians and athletes) from their personal activities as such may be taxed in the Contracting State in which these activities are exercised.

2.         Where income in respect of the personal activities of an entertainer as such accrues not to that entertainer 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 are exercised.

3.         Notwithstanding the provisions of Article 7, where the activities mentioned in paragraph 1 are provided in one of the Contracting States 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 State unless the enterprise is substantially supported by public funds of the other State, including any political subdivision, local authority or statutory body thereof, in connection with the provision of such activities.

4.         The provisions of paragraphs 1 and 2 shall not apply to income derived from activities performed in a Contracting State by entertainers if the visit to that Contracting State is substantially supported by public funds of the other Contracting State, including any political subdivision, local authority or statutory body thereof.

ARTICLE 18
PENSIONS AND ANNUITIES

1.         Subject to the provisions of Article 19, pensions and annuities paid to a resident of one of the Contracting States shall be taxable only in that State.

2.         The term "annuity" means a stated sum 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.

ARTICLE 19
GOVERNMENT SERVICE

1.         Remuneration (other than a pension) paid by one of the Contracting States or a political subdivision of that State or a local authority of that State to any individual in respect of services rendered in the discharge of governmental functions shall be taxable only in that State.  However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State and the recipient is a resident of that other State who:

            (a)        is a citizen or national of that other State; or

            (b)        did not become a resident of that other State solely for  the purpose of

                         performing the services.

2.         Any pension paid to an individual in respect of services rendered in the discharge of governmental functions to one of the Contracting States or a political subdivision of that State or a local authority of that State shall be taxable only in that State.  Such pension shall, however, be taxable only in the other Contracting State if the recipient is a resident of, and a citizen or national of, that other State.

3.         The provisions of paragraphs 1 and 2 shall not apply to remuneration or a pension in respect of services rendered in connection with any trade or business carried on by one of the Contracting States or a political subdivision of one of the States or a local authority of one of the States.  In such a case, the provisions of Article 15, 16 or 18 as the case may be shall apply.

ARTICLE 20
PROFESSORS AND TEACHERS

1.         A professor  or teacher who is a resident of one of the Contracting States and who visits the other Contracting State,  at the invitation of any university, college, school or other similar educational institution situated in the other Contracting State and which is recognized by the competent authority of that other State, for a period not exceeding two years solely for the purpose of teaching or research or  both at such educational institution shall be taxable only in the first mentioned state on any remuneration for such teaching or research.

2.         This Article shall not apply to remuneration which a professor or teacher receives for conducting research if the research is undertaken primarily for the private benefit of a specific person or persons.

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