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c) The remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other State.

3 — Notwithstanding the preceding provisions of this article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

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 supervisory board (in Portugal, conselho fiscal) or of another similar organ of a company which is a resident of the other Contracting State may be taxed in that other State, provided that remuneration paid by that company to a member of its organs in respect of the exercise of a continuous activity shall be taxable according to the provisions of article 15.

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 telewsion airtict, 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 capac-ity as such accrues not to the entertainer or athlete 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 athlete are exercised.

3 — The provisions of paragraph 2 shall not apply if it is established that neither the entertainer or the athlete nor persons with whom he is not dealing at arm's length, participate directly or indirectly in the profits of that other person referred to in that paragraph.

ARTICLE 18 (Pensions)

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.

ARTICLE 19 (Government service)

I:

a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to any individual in respect of services rendered to that State

or subdivision or authority shall be taxable only in that State; b) However, such 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:

f) Is a national of that State; or //) 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 of aay individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State;

b) However, such pensions 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, 17 and 18 shall qppfy to remuneration and .pensions an '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)

1 — Payments which a siturient or business, technical, agricultural or forestry apprentice who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training receives for the purpose of his maintenance, education or training shall not be taxed in that State, provided that such payments arise from sources outside that State.

2 — A student at a university or other institution for higher education in a Contracting State, or a business, technical, agricultural or a forestry apprentice who is present in the other Contracting State for a period' or periods not exceeding 183 days in the calendar year concerned and who is or was immediately bafone such visit a resident of the first-mentioned State, shall not be taxed in the other Contracting State in ■respect of remuneaaiiion for services rendered in that other State, provided that the services are in connection with his studies or training and the remuneration constitutes earnings necessary for his maintenance.

ARTICLE 21 (Other Income)

1 — Items of income of a resident of a Contracting State, arising in the other Contracting State, not dealt with in the foregoing art teles cf this Convention, may be taxed in that other State.

2 — The provisions of article 7 or article 14, as the case may be, shall apply to the income, wherever arising, not dealt with in the foregoing articles of this Convention, other than income from immovable prop-