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442
ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
be deemed not
to aoorue to another
Ρθτβοη
if
1t
18
established
that neither the entertainer
οτ
athlete,
ηοτ
persons related
thereto, participate directly or indirectly
ίη
the profits
ο!
such other person in
any
manner, including the reoeipt
of
deferred remuneration, bonuses, fees, dividends, partnership
distributions or other distributions.
Article
20
DIRECTORS' FEES
Fees derived
by
a
resident
ο!
a
Contracting State
ίη
his capaci ty
βΒ
a menIber of the board
ο! dir~ctors ο!
a
corporation
ο!
the other Contracting State (but not
including fixed or contigent paynlents derived
ίη
his
cβρβcί
ty
βΒ
an
officer or enJployee) may,
Ιο
the extent
such fees are
ίη
excess of
a
reasonable fixed amount for
each day
ο!
attendance payab1e
Ιο
a11 directors
ο!
the
corporation for attendance at the directors' meeting
ίη
such other Contracting State, be taxab1e
ίη
such other
Contracting state.
Article 21
STUDENTS
AND
TRi~INEES
(1) (a)
An
individual
V\oho
ίΒ
a
resident
ο!
a
Contracting
State at the time he becomes temporarily
pr~sent ίη
the other Contracting State
and v\'ho
i5 tenlporari1y
present
ίη
that other Contracting State
ίοτ
the
primary purpose
of:
(i)
Studying at
a
university or other recognized
educational institution
ίη
that other Contracting
State;
οτ
(11)
Securing training required to qualify himto
.
practive a profession or professional specialtYj
or
(ii1) Studying or doing research
βθ
a recipient of
8
grant, allowance,
οτ
award from a governmental,
re1igious, charitable, scientific, literary, or
educational organization;
shall be exeULpt from tax by that other Contracting
State
tor
a period not exceeding five taxable years