1004-(62)

II SÉRIE-A — NUMERO 41

b) The remuneration is paid by, or on behalf of, an employer who is not a resident of the other State; and

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, aircraft or road vehicle 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 any similar organ of a company which is a resident of the other Contracting State may be taxed in that other State.

Article 17 Artistes and sportsmen

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 television artiste, or a musician, or as a sportsman 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 a sportsman in his capacity as such accrues not to the entertainer or sportsman himself but to another person, that income may, notwithstanding the provision of articles 7, 14 and 15, be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised.

3 — Notwithstanding the provisions of paragraphs 1 and 2 of this article, income mentioned in this article shall be exempt from tax in the Contracting State in which the activity of the entertainer or sportsman is exercised provided that this activity is supported for the most part out of public funds of this State or of the other State or the activity is exercised under a cultural agreement or arrangement between the Contracting States.

Article 18

Pensions

1 — Subject to the provisions of paragraph 2 of article 19, pensions, annuities and other similar remuneration paid to a resident of a Contracting State in consideration of past employment 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 a commitment with an obligation to make the payments in return for adequate and full consideration in money or money's worth.

Article 19

Government service

1 — a) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State,

a political or administrative subdivision, a local authority, or an administrative-territorial unit thereof to an individual in respect of services rendered to that State or subdivision, authority or unit shall be taxable only in that State.

b) However, such salaries, wages and other similar 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:

i) 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 or administrative subdivision, a local authority or an administrative-territorial unit thereof to an individual in respect of services rendered to that State or subdivision, authority or unit shall be taxable only in that State.

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, 17 and 18 shall apply to, salaries, wages and other similar remuneration, and to pensions, in respect of services rendered in connection with a business carried on by a Contracting State, a political or administrative subdivision, a local authority or an administrative-territorial unit thereof.

Article 20 Professors and researchers

1 — 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.

2 — The provisions of paragraph 1 of this article shall not apply to income from research if such research is undertaken not in the public interest but for the private benefit of a specific person or persons.

Article 21

Students and trainees

1 — Payments which a student or trainee 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 — Remuneration paid to a student or trainee resident of a Contracting State for the purposes referred