Article 14-18

1.

Income derived by an individual who is a resident of a Contracting State from the performance of personal services in an independent capacity shall be taxable only in that State,

a)

such services are performed or were performed in the other Contracting State;

b)

the income is attributable to a fixed base that the individual has or had regularly available to him in that other State. In such a case, the income attributable to that fixed base may be taxed in that other State in accordance with principles similar to those of Article 7 (Business profits) for determining the amount of business profits and attributing business profits to a permanent establishment.

2.

The term ``independent personal services'' includes especially independent scientific, literary, artistic, educational or teaching activities, as well as the independent services of physicians, lawyers, engineers, architects, dentists, and accountants.

1.

Subject to the provisions of Articles 18 (Government Service) , and 19 (pensions) , salaries, wages, and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.

2.

Notwithstanding the provisions of paragraph 1 of this Article, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if

a)

the recipient is present in the other State for a period or periods not exceeding in the aggregate 163 days in the taxable year concerned; and

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 that the employer has in the other State.

3.

Remuneration derived by a resident of a Contracting State that would otherwise be taxable in the other Contracting State under the preceding provisions of this Article may be taxed only in' the first-mentioned State when the remuneration is in respect of employment as a member of the regular complement of a ship or aircraft operated in international traffic.

Directors' fees and similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or similar body of a company that is a resident of the other Contracting State may be taxed in that other State except to the extent that they are remuneration for services rendered in the first-mentioned State.

1.

Notwithstanding the provisions of Articles 14 (Independent Personal Services) and 15 (Dependent Personal Services), income derived by a resident of a Contracting State as an entertainer, such as a theater, 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 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 (Business Profits), 14 (Independent Personal Services) and 15 (Dependent Personal Services), be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised. or purposes of the preceding sentence, income of an entertainer or sportsman shall be deemed not to accrue to another person if it is established that neither the entertainer or sportsman, nor persons related thereto, participate directly or indirectly in the profits of such other person in any manner, including the receipt of deferred remuneration, bonuses, fees, dividends, partnership distributions or other distributions.

3.

Notwithstanding the provisions of paragraphs 1 and 2, income derived by a resident of a Contracting State as an entertainer or sportsman shall be exempt from tax by the other Contracting State if the visit to that other State is substantially supported by public funds of the first-mentioned State or a political subdivision or local authority thereof or is made pursuant to a specific arrangement agreed to by the Governments of the Contracting States.

1.

a)

Remuneration, Other than a pension, paid from the public funds of a Contracting State, a political 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

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.

a)

Any pension paid by, or out of funds created by, a Contracting State, a political subdivision or local authority of that State to an individual in respect of services rendered to that State, subdivision, or authority shall be taxable only in that State.

b)

However, such pension may also be taxed in the other Contracting State if the individual is a resident of, and a citizen of, that other State.

3.

Notwithstanding the provisions of paragraphs 1 and 2, the provisions of Article 14 (Independent Personal Services), Article 15 (Dependent Personal Services), or Article 19 (Pensions), as the case may be, shall apply to remuneration paid in respect of services rendered in connection with a business.

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