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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.         The remuneration which a person to whom paragraph 1 applies derives from  the  company  in  respect of the discharge of day-to-day functions of a managerial or technical nature may be taxed in accordance with the provisions of Article 15.

 

 

ARTICLE 17
ARTISTES AND ATHLETES

1.         Notwithstanding the provisions of Article 15, income derived by a resident  of  a Contracting State as an entertainer, such as a theater, 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 that entertainer  or  athlete  himself  but  to  another  person,  that income may, notwithstanding the provisions of Articles 7 and 15, be taxed in the Contracting State in which the activities of the entertainer or athlete 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 by an entertainer  or  an  athlete  if  the  visit  to  that  Contracting  State  is substantially  supported  by  public  funds  of  the  other Contracting State, including those of any political subdivision, local authority or statutory body thereof,  nor to in income derived by a non-profit organization in respect of such  activities provided no part of its income is payable to, or is otherwise available for the personal benefit of its proprietors, members of shareholders and  the  organization  is certified as qualifying under this provision by the competent authority of the other State.

 

4.         Notwithstanding the provisions of Article 7, where the activities mentioned in paragraph 1 of this Article 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  unless  the enterprise is substantially supported from the public funds of the other Contracting State, including any political subdivision, local authority or statutory body thereof, in connection with the provisions of  such  activities,  or  unless  the enterprise is a non-profit organization referred to in paragraph

 

 

ARTICLE 18
PENSIONS

1.         Subject to the provisions of paragraph 1 of Article 19, pensions and other similar remuneration for past employment arising in a Contracting State shall be taxable only in that State.

 

2.         The term "pensions" as used in this Article means periodic payments made in consideration for past services rendered.

 

 

ARTICLE 19  
GOVERNMENTAL FUNCTIONS

1.         Remuneration including pension paid by or out of public funds of a Contracting  State  or a political subdivision or local authority or statutory body thereof to:

            (a)        national of that Contracting State;

            (b)        an individual who is not national of the other Contracting

                         State and  goes  to  the other State solely for the purpose of

                         being engaged by the first-mentioned State,for  services

                         rendered  to that State in the discharge of functions of a

                         governmental nature shall be exempt from tax in the other

                         State.

 

2.         The  provisions  of  paragraph  1 shall not apply to remuneration including  pension paid in respect of services rendered in connection with any trade or business carried on by a Contracting State or a political subdivision or local authority or statutory body thereof.

 

 

ARTICLE 20
TEACHERS AND RESEARCHERS

1.         An individual who is a resident of a Contracting State immediately before making a visit to the other Contracting State, and who, at the invitation of  any university, college, school or other similar educational institution, which is recognized by the competent authority in that other Contracting State, visits that other Contracting State for a period not exceeding two years solely for the purpose of teaching or research or both at such educational institution shall be exempt from tax in that other Contracting State on his remuneration for such teaching or research.

 

2.         This Article shall not apply to income from research if such research in taken under not in the general interest but primarily for the private benefit of a specific person or persons.

 

 

Last updated: 08.12.2011