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aggregate 183 days in the calendar year concerned, and

b) The remuneration is paid by, or on behalf of,

am employer who is not a resident of the other State; and

c) The remuneration is not borne by a perma-

nent 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

Director's fees and other similar payments derived by a resident of a Contraotin State in his capacity as a member cf 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 com-, pany 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 previsions of Article 14 and 15 income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion pioture, radio or television artist, 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 athete 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 entretainer or athlete are exercised.

ARTICLE 18

Pensions

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

1 — Subject to the provisions of Article 18, remuneration paid by, or cut of funds created by a Contiacting State, a Land, a policial subdivision or a

local authority thereof to any individual in respect of an employment shall be taxable only in that State. If, however, the employment is exercised in the other Contracting State by a national of that State not being a national of the first-mentoned State, the remuneration shall be taxable only in that other State,

2 — The provisions of Articles 15, 16 and 17 shall apply to remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a Land or a political subdivision or a local authority thereof.

ARTICLE 20 Professors

Subject to the provisions of article 19, a professor or teacher who is or was immediately before a resident of a Contracting State and who, at the invitation of the Governament of the other Contracting State or of a non profit-making university or other approved non profit-making educational, institution of that other Coimtra'cting State, or under an official programme of cultural exchange, visits that other State for a period not exceding two years solely for the purpose of teaching, carrying out research or giving lectures undertaken in the public interest at such a university or educational institution shall be exempt from tax in that other State on his remuneration from such activity, provided that suck remuneration is derived from outside that other State.

ARTICLE 21

Students

1 — An individual who is or was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that other State solely as a student at a university, college, school or other similar educational institution in that other State or as business, agricultural, forestry or technical apprentice (including in the case of the Federal Republic of Germany a Volontär or a Praktikant) shall from the date of his first arrival, in that other Stalte in connection with that visit, be exempt from tax in that other State on:

a) All remittances from abroad for purposes of

his maintenance, education or training; and

b) For a period not exceeding in the aggregate

three years, on any remuneration not exceeding 7200 DM or the equivalent in Portuguese currency for the calendar year, for personal services rendered in that other State with a view to supplement the resources available to him for his naintenance, education or training.

2 — An individual who, is or was a resident of a Contracting State immediately before visiting the other Contracting State and is temporarily present in that other Contracting State solely for the purpose of study, reserarch or training as a recipient of a gramr, allowance or award from a scientific, educational, religious or charitable organization or under