ARTICLE 16
DIRECTORS FEES
Directors fees and other similar payments derived by a resident of a Contracting State in his capacity as, or on behalf of, 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 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. The provisions of paragraphs 1 and 2 of this Article shall not apply to income derived from activities performed by an entertainer or a sportsman, or provided by an enterprise of a Contracting State in a Contracting State if the visit to that Contracting State, or the enterprise, as the case may be, is substantially supported by public fund of the other Contracting State, including any local authority thereof.
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 State.
ARTICLE 19
GOVERNMENTAL SERVICE
1. (a) Salaries, wages and other similar remuneration, other than a pension, paid by
a Contracting State or a local authority thereof to an individual in respect of
services rendered to that State or authority 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
(ii) 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 local
authority thereof to an individual in respect of services rendered to that State or
authority 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 and 18 shall apply to salaries, wages, other similar remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a local authority thereof.
ARTICLE 20
STUDENTS
An individual who is or was immediately before visiting a Contracting State a resident of the other Contracting State and whose visit to the first-mentioned Contracting State is solely for the purpose of:
(a) studying at a university or other recognized educational institution; or
(b) securing training to qualify him to practise a profession; or
(c) studying or carrying out research as a recipient of a grant, allowance or
award from a governmental, religious, charitable, scientific, literary or
educational organization;
shall be exempt from tax in the first-mentioned State on :
(i) remittances from abroad for the purposes of his maintenance, education, study,
research or training;
(ii) the grant, allowance or award. | 
