Article 17-21

1.

a)

Remuneration, other than a pension, paid from the public funds of a Contracting State, a subdivision or local authority thereof to an individual in respect of services rendered in the discharge of functions of a governmental nature shall be taxable only in that State.

b)

However, such 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 citizen of that State; or

ii)

did not become a resident of that State solely for the purpose of rendering the services.

2.

Notwithstanding the provisions of paragraph 1, the provisions of Article 14 (Independent Personal Services) or Article 15 (Income from Employment), as the case may be, shall apply to remuneration paid in respect of services rendered in connection with a business.

1.

Subject to the provisions of paragraph 2,

a)

pensions and similar remuneration derived and beneficially owned by a resident of a Contracting State in consideration of past employment may be taxed only in that State; and

b)

social security benefits and other public pensions paid by a Contracting State may be taxed only in that State.

a)

Any pension paid to an individual in respect of services rendered to a Contracting State, subdivision, or authority in the discharge of functions of a governmental nature and paid by, or out of funds created by, that State, subdivision or local authority 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 citizen of, that other Contracting State.

3.

Annuities derived and beneficially owned by an individual who is a resident of a Contracting State shall be taxable only in that State. The term ``annuities'' as used in this paragraph means a stated sum paid periodically as stated times during a specified number of years, under an obligation to make the payments in return for adequate and full consideration (other than services rendered.)

4.

Alimony paid to a resident of a Contracting State shall be taxable only in that State. The term ``alimony'' as used in this paragraph means periodic payments made pursuant to a written separation agreement or a decree of divorce, separate maintenance, or compulsory support, which payments are taxable to the recipient under the laws of the State of which he is a resident.

5.

Periodic payments for the support of a minor child made pursuant to a written separation agreement or a decree of divorce, separate maintenance, or compulsory support, paid by a resident of a Contracting State to a resident of the other Contracting State shall be taxable only in the first-mentioned State.

ARTICLE 19
Students. Trainees and Researchers

1.

An individual who is a resident of a Contracting State at the beginning of his visit to the other Contracting State and who is temporarily present in that other State for the primary purpose of:

a)

studying at a university or other accredited educational institution in that other State, or

b)

securing training required to qualify him to practice a profession or professional specialty, or

c)

studying or doing research as a recipient of a grant, allowance, or other similar payments from a governmental, religious, charitable, scientific, literary, or educational organization, shall be exempt from tax by that other State with respect to payments from abroad for the purpose of his maintenance, education, study, research, or training, and with respect to the grant, allowance, or other similar payments.

2.

The exemption in paragraph 1 shall apply only for such period of time as is ordinarily necessary to complete the study, training or research, except that no exemption for training and/or research shall extend for a period exceeding five years.

3.

This Article 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 20
Other Income

Items of income of a resident of a Contracting State, arising in the other Contracting State and not dealt with in the foregoing Articles of this Convention, may be taxed in that other State.

1.

A person that is a resident of a Contracting State and derives income from the other Contracting State shall be entitled under this Convention to relief from taxation in that other State only if such person

a)

an individual;

b)

engaged in the active conduct of business in the first-mentioned State (other than the business of making or managing investments, unless these activities are banking or insurance activities carried on by a bank or insurance company), and the income derived from that other State is derived in connection with, or is incidental to, that business;

c)

a company the shares of which are traded in the first-mentioned State on a substantial and regular basis on an officially recognized securities exchange or a company which is wholly owned, directly or indirectly, by another company that is a resident of the first-mentioned State and the shares of which are so traded;

d)

a not-for-profit organization that is generally exempt from income taxation in its Contracting State of residence, provided that more than half of the beneficiaries, members or participants, if any, in such organization are entitled, under this Article, to the benefits of this Convention; or

e)

a person that satisfies both of the following conditions:

i)

more than 50 percent of the beneficial interest in such person, or in the case of a company, more than 50 percent of the number of shares of each class of the company's shares, is owned directly or indirectly by persons entitled to the benefits of this Convention under subparagraphs a), c) or d), and

ii)

not more than 50 percent of the gross income of such person is used, directly or indirectly, to meet liabilities (including liabilities for interest or royalties) to persons not entitled to the benefits of this Convention under subparagraphs a), c) or d).

2.

A person that is not entitled to the benefits of the Convention pursuant to the provisions of paragraph 1 may, nevertheless, be granted the benefits of the Convention if the competent authority of the State in which the income arises so determines.

3.

For purposes of subparagraph (e) (ii) of paragraph 1, the term ``gross income'' means gross receipts, or where a person is engaged in a business which includes the manufacture or production of goods, gross receipts reduced by the direct costs of labor and materials attributable to such manufacture or production and paid or payable out of such receipts.

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