1636-(24)

II SÉRIE-A — NÚMERO 56

the aggregate 183 days in the calendar year concerned; and

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

c) The remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting 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 by an enterprise of a Contracting State, may be taxed in that Contracting State.

Article 16

Director's fees

1 — Director's 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 Contracting State.

2'— Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official in a top-level managerial position of a company which is a resident of the other Contracting State may be taxed in that other Contracting State.

Article 17

Artists 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 artist 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 Contracting 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 provisions 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 mainly supported by this Contracting State or by the other Contracting State or the activity is exercised under a cultural agreement or arrangement between the Contracting States.

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 Contracting State.

Article 19

Government service

1 — a) Salaries, wages and other similar remuneration, other than a pension, paid by the Government

of a Contracting State or an administrative subdivision or a local authority thereof to an individual in respect of services rendered to that Contracting State or subdivision or authority thereof shall be taxable only in that Contracting 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 other Contracting State and the individual is a resident of that other Contracting State who:

i) Is a national of that Contracting State; or

ii) Did not become a resident of that Contracting State solely for the purpose of rendering the services.

2 — o) Any pension paid by, or out of funds created by the Government of a Contracting State or an administrative subdivision or a local authority thereof to an individual in respect of services rendered to that Contracting State or subdivision or authority thereof shall be taxable only in that Contracting 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 other Contracting 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 the Government of a Contracting State or an administrative subdivision or a local authority thereof.

Article 20 Teachers and researchers

1 — An individual who is, or immediately before visiting a Contracting State, was a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of teaching, giving lectures or conducting research at a university, college, school or other similar educational institution or scientific research institution accredited by the Government of the first-mentioned Contracting State and is recognised as non-profitable by that Government of the first-mentioned Contracting State or under an official programme of cultural exchange shall be exempt from tax in the first-mentioned Contracting State, for a period of three years from the date of his first arrival in the first-mentioned Contracting State, in respect of remuneration for such teaching, lectures or research.

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

Article 21

Students and trainees

A student, business apprentice 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 shall be exempt from tax in that first-mentioned State on the following payments or income received or derived by him for the purpose of his maintenance, education or training:

a) Payments derived from sources outside that Contracting State for the purpose of his maintenance, education, study, research or training;