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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 above, 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 183 days in the fiscal 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 deducted from the profits of a permanent establishment or a fixed base which the employer has in the other State.

3. Notwithstanding the preceding provisions of this article, remuneration for personal services performed aboard a ship or aircraft in international traffic, may be taxed in the Contracting State in which the place of effective management of the enterprise is situated.

Article XI. 1. Remuneration, including pensions, paid by or out of funds created by a Contracting State or a local authority thereof to any individual in respect of services rendered to that State, or local authority thereof in the discharge of functions of a governmental nature may be taxed in that State. They shall not be taxed in the other Contracting State if the payment is made to a citizen of the first mentioned State.

2. The provisions of articles VIII, X, and XII shall apply to remuneration and pensions in respect of services rendered in connection with any trade or business carried on by one of the Contracting States or a local authority thereof.

3. In this article and article XII, the term "pension" means periodic payments made in consideration of past services or by way of compensation for injuries received.

Article XII. 1. Subject to the provisions of paragraph 1 of article XI, pensions and other similar remuneration paid in consideration of past employment and annuities shall be taxable only in the Contracting State of which the recipient is a resident.

2. In this article 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 XIII. Notwithstanding anything contained in this Convention, income derived by public entertainers, such as theatre, motion pictures, radio or television artists and musicians, and by athletes, from their personal activities as such may be taxed in the Contracting State in which these activities are exercised.

Article XIV. A resident of one of the Contracting States who, at the invitation of a university, college or other establishment for higher education or scientific research in the other Contracting State visits that other Contracting State solely for the purpose of teaching or scientific research at such institutions,Vol. 1332, I-22351