Document ID: chunk:federal_register_of_legislation:C2024C00814:schedule:1:p14
Version: federal_register_of_legislation:C2024C00814
Segment Type: schedule
Provision Reference: sch 1 (pt 14/31)
Character Range: 118622–121424

aggregate 183 days in any twelve month period commencing or ending in the year of income concerned; and
         (b) the remuneration is paid by, or on behalf of, an employer who is not a resident of that other territory; and
         (c) the remuneration is not deductible in determining taxable profits of a permanent establishment or a fixed base which the employer has in that other territory; and
         (d) the remuneration is, or upon the application of this Article will be, subject to tax in the first‑mentioned territory.

3. Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated by an enterprise of a territory in international traffic shall be taxable only in that territory.

Article 16
Directors' fees

Directors' fees and similar payments derived by a resident of a territory in the person's capacity as a member of the board of directors of a company which is a resident of the other territory may be taxed in that other territory.

Article 17
Entertainers and sportspersons

1. Notwithstanding the provisions of Articles 14 and 15, income derived by entertainers (such as theatrical, motion picture, radio or television artistes and musicians) and sportspersons from their personal activities as such may be taxed in the territory in which these activities are exercised.

2. Where income in respect of the personal activities of an entertainer or a sportsperson as such accrues not to that entertainer or sportsperson but to another person, that income may, notwithstanding the provisions of Articles 7, 14 and 15, be taxed in the territory in which the activities of the entertainer or sportsperson are exercised.

Article 18
Pensions and annuities

1. All pensions and annuities paid to a resident of a territory shall be taxable only in that territory.

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.

Article 19
Public service

1. Salaries, wages and other similar remuneration, other than a pension or annuity, paid by an authority administering a territory or a subdivision of that territory or by a local authority of that territory to any individual in respect of services rendered in the discharge of public or administrative functions on behalf of such an authority shall be taxable only in that territory. However, such salaries, wages and other similar remuneration shall be taxable only in the other territory if the services are rendered in that other territory and the recipient is a resident of that other territory who:
         (a) is a citizen