Document ID: chunk:federal_register_of_legislation:C2004A04052:schedule:29:p37
Version: federal_register_of_legislation:C2004A04052
Segment Type: schedule
Provision Reference: sch 29 (pt 37/64)
Character Range: 93305–96046

these activities are exercised.

(2) Where income in respect of personal activities exercised by an entertainer as such accrues not to that entertainer 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 are exercised.

(3) Notwithstanding the provisions of paragraph (1), income derived by an entertainer from his or her personal activities as such in one of the Contracting States shall be taxable only in the other Contracting State if those activities in the first-mentioned State are supported substantially from the public funds of that other State or of one of its political subdivisions or local authorities.

SCHEDULE 2—continued

(4) Notwithstanding the provisions of paragraph (2) and Articles 7, 14 and 15, where income in respect of personal activities exercised by an entertainer as such in one of the Contracting States accrues not to that entertainer but to another person, that income shall be taxable only in the other Contracting State if that other person is supported substantially from the public funds of that other State or of one of its political subdivisions or local authorities, or if that person is a non-profit organisation of that other State.

ARTICLE 18

Pensions and Annuities

(1) Pensions (other than pensions to which Article 19 applies) and annuities paid to a resident of one of the Contracting States shall be taxable only in that State.

(2) The term "annuity" means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money's worth.

(3) Any alimony or other maintenance payment arising in one of the Contracting States and paid to a resident of the other Contracting State shall be taxable only in the first-mentioned State.

ARTICLE 19

Government Service

(1) Remuneration, other than a pension or annuity, paid by one of the Contracting States or a political subdivision or local authority of that State to any individual in respect of services rendered in the discharge of governmental functions shall be taxable only in that State. However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State and the recipient is a resident of that other State who:

  (a) is a citizen or national of that State; or

     (b) did not become a resident of that State solely for the purpose of performing the services.

     (2) (a) Any pension paid by, or out of funds created by, one of the Contracting States or a political subdivision or local authority