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II SÉRIE-A — NÚMERO 61

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 remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a political or administrative subdivision or a local authority thereof.

Article 20 Students

Payments which a student or business 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.

Article 21 Professors and researches

Remuneration received for teaching or scientific research by an individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first State during a period not exceeding two years for the purpose of scientific research or for teaching at a university, college, establishment for higher education, research institute or other similar establishment accredited by the Government of the other Contracting State shall be exempt from tax in the first State provided that all such entities have non-profitmaking purposes and the income is derived from abroad.

Article 22

Other income

1 —Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing articles of this Convention shall be taxable only in that State.

2 — The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of article 7 or article 14, as the case may be, shall apply.

Article 23 Elimination of double taxation

The double taxation shall be eliminated as follows:

a) In the Portuguese Republic:

i) Where a resident of Portugal derives income which, in accordance with the

provisions of this Convention may be taxed in the Czech Republic, Portugal shall allow as a deduction from the tax on the income of that resident an amount equal to the income tax paid in the Czech Republic.'Such deduction shall not, however, exceed that part of the income tax as computed before the deduction is given, which is attributable to the income which may be taxed in the Czech Republic;

ii) Where in accordance with any provision of the Convention income derived by a resident of Portugal is exempt from tax in this State, Portugal may nevertheless, in calculating the amount of tax on the remaining income of such resident, take into account the exempted income;

b) In the Czech Republic:

i) The Czech Republic, when imposing taxes on its residents, may include in the tax base upon which such taxes are imposed the items of income which according to the provisions of this Convention may also be taxed in Portugal, but shall allow as a deduction from the amount of tax computed on such a base an amount equal to the tax paid in Portugal. Such deduction shall not, however, exceed that part of the Czech tax, as computed before the deduction is given, which is appropriate to the income which, in accordance with the provisions of this Convention, may be taxed in Portugal;

ii) Where in accordance with any provision of the Convention or the domestic law income derived by a resident of the Czech Republic is exempt from tax in this State, the Czech Republic may nevertheless, in calculating the amount of tax on fhe remaining income of such resident, take into account the exempted income.

Article 24 Non-discrimination

1 — Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other State in the same circumstances, in particular with respect to residence, are or may be subjected. This provision shall, notwithstanding the provisions of article 1, also apply to* persons who are not residents of one or both of the Contracting States.

2 — The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other State than the taxation levied on enterprises of that other State carrying on the same activities. This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reduc-