2. Notwithstanding the provisions of paragraph 1, pensions and other similar

remuneration paid by, or out of funds created by, a Contracting State or a political or

administrative subdivision or a local authority thereof to an individual in respect of

services rendered to that State or subdivision or authority shall be taxable only in that

State. However, such pensions and other similar remuneration 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,

pensions, and other similar remunerationin 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

PROFESSORS AND RESEARCHERS

An individual who is or was a resident of a Contracting State immediately before

visiting the other Contracting State, solely for the purpose of teaching or scientific

research at an university, college, school, or other similar educational or scientific

research institution which is recognized as a non-profit entity by the Government of that

other State, or under an official programme of cultural exchange, for a period not

exceeding two years from the date of his first arrival in that other State, shall be exempt

from tax in that other State on his remuneration for such teaching or research.

ARTICLE 21

STUDENTS

Payments which a student or traineewho 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 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 a 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 a case the provisions of Article 7 or

Article 14, as the case may be, shall apply.

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