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204 ΕΠΙΣΗΜΟΣ ΕΦΗΜΕΡΙΣ ΤΗΣ 26ης ΦΕΒΡΟΥΑΡΙΟΥ 1982
2. The term "ΡrοfessίΌnal services" includes,
especially independent scientific, literary, artistic,
educational orteaching activities as well as the
independent activities σί physicians, lawyers,
engineers, architects, dentists and accountants. ι
Article 16
ΟΕΡΕΝΟΕΝΤ PERSONAL SERVICES
1. Subject to the provisions of Art:icles 17, 19
and 20, saΙaήes, wagesand other similar remune–
ration derived by a resident οί a ContraCΙing
State ίη respect οί an employment shall be
taxable οηlΥ ίη that State unless the employment
is exercised ίη 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 οί pa.ragraph
1, remuneration derived by a resident οί a
Contracting State ίη respeot οί an employment
exercised ίη the other Contracting State sha11 be
taxable only ίη the first-mentioned State iί;
(a) the recipient is present ίη ,the other State
for a period or periods ηοΙ exceeding ίη
the aggregate 183 days ίη the calendar
year concerned, and
(b )the remuneration is paίd by, or οη be–
half οι an employer who is ηοΙ a resident
οί the other State, and
(c) the remuneration is ησΙ ,borne ,by a ρer­
manent establishment or a fixed base
which the employer has ίη the other State.
3. Notwithstanding the preceding ,provisions of
this Article, remuneration ίη respect of an em–
ployment exercised aboard a ship, aircraft, or
road vehicle operated ίη international traffic, may
be taxed ίη the Contracting State ίη which the
place οί effective management of the enterprise
is situated.
Article 17
DIRECTORS' FEBS
Directors' fees and other similar payments
derived by a resident of a Contracting State ίη
his capacity as a member of the ;board of directors
or another simiIar organ of a company which is
a resident of the other Contracting State may be
taxed ίη that other State.
Article 18
ARTISTES ΑΝΟ ATHLETES
Notwithstanding the provisions of Articles 15
and 16, income derived by a resident οί a
Contracting State as an entertaίner, such as a
theatre, motion picture, radio or television artiste,
or a musician, or as an athIete, from his persona1
activities as such exercised ίη the other Contract–
ing State, may be taxed ίη that other State. How–
ever, income derived from such activities shall be
exempt from tax ίη that State ίf the activities are
perfoπned under a cultural agreement or arrange–
ment between the Contracting States.
Article 19
GOVERNMENT SERVlCES
1. Remuneration. other than a pension, paid
by a Contracting State or aπ administrative terri–
torial unit or a local authority thereof to an indi–
vidual ίη respect of services rendered Ιο that State
or subdivision or authority shall be 'taxable οηlΥ
ίη that State.
2. However. remuneration referred Ιο ίη pa–
ragraph 1 shall be taxable οηlΥ ίη the other
Contracting State if the services are rendered ίη
that State and the individual is a resident of that
State who :
(a) is a national of that State; οτ
(b) did not become a resident οί that State
sole~y for the purpose οί rendeήng the
servrces.
3 (a) ΑηΥ pension paid by, or out οί funds
created 'by, a Contracting State or an
administrative territoriaιl uni:t or a local
authority thereof Ιο an individua1 ίη
respect οί services rendered to that State
administrative territorial unit or 10cal
authority, sha11 be taxaιble only ίη that
State.
(b) However, such pension shall be taxable
οηlΥίη the other Contracting State ίί the
individual is a resident οί, and a national
οί, that State.
4. The provisions οί paragraphs 1 and 2 shall
not apply Ιο remuneratίon in respect of services
rendered ίη connection with a business car,ried οη
by a Contracting State or an administrative terri–
torial unit or a local authority thereof.
Article 20
PENSIONS
Subject Ιο the provisions οί paragrap~ (2) of
Article 19 pensions, annuities and other similar
remuneration paid ,to a resident οΙ a Contracting
State shall be taxable οηlΥ ίη that State.
Article 21
STUDENTS
1. Payments which a s.tudent or business
apprentice who j,s present ίη a Contracting 'State
solely for the purpose οί his education or training
'and who is or was immediately before such visit
a resident οί the other Contracting State received
for the purpose οί his maintenance, education or
training shall not be taxedin the first-mentioned
Contracting State, provided that 'such payments
are made Ιο him from sources ou.tside ιΜι State.
2. Α student at a univelisity or other ίηstίωtίοn
for higher education ίη a Contracting State, or a
business apprentice who is present ίη the other
tContracting State for a period or periods ηαΙ
exceeding 183 day,s ίη the ca1endar year concerned
and who is or was immediately ,before such visit
a resident οί the fir,st-mentioned State, sha11 παΙ
be taxed ίη the other ContracNng State ίη respect
of remuneration for services rendered ίη that other
State, provided that the services are ίη connection
with his studies or traίning andthe remuneration
oonstitutes eamings necessary for his maintenancc.
Article 22 •
TEACHERS
1. Α professor or teacher resident οί a
Contracting State who is engaged ίη teaching or
research ata university or at any other approved
educational ,institution of the other Contracting
State sha11 be taxable οηlΥίη the first Contracting
State οη all remuneration received ίη respect of
,that activity for a p'eriod not exceeding two years
from the beginning οί thei,r activity.
2. The provisions of paragraph 1 shall ησΙ
apply Ιο income from research, ίί such research ,
is undertaken ηοΙ ίη the pu'b1ic interest but pri–
marily for the private benefit of a specific person
or persons.
Article 23
INCOME ΝΟΤ EXPRESSLγ ΜΕΝΤΙΟΝΕΟ
Items οί income of a resident οί a Contracting
State which are ησΙ expressly mentioned ίη the
foregoing Articles οί this Convention shaH be
taxable οηlΥ inthat State.
Article 24
CAPITAL
1. Capital represented ,by immovaιble ,property,
as defined ίη paragraph 2 οί Article 6, may be
taxed ίη the Contracting State ίn which such
immovable property is · situated.