2. a) Notwithstanding the provisions of paragraph 1, pensions and other similar
remuneration paid by, or out of funds created by, a Contracting State or a political
subdivision or a local authority thereof to an individual in respect of services
rendered to that State or subdivision or authority shall be taxable only in that
State.
b) However, such pensions and other similar remuneration shall be taxable only in
the other Contracting State if the individual is a resident of, and a national of,
that State.
3. The provisions of Articles 15, 16, 17, and 18 shall apply to salaries, wages,
pensions, and other similar remuneration in respect of services rendered in
connection with a business carried on by a Contracting State or a political subdivision
or a local authority thereof.
ARTICLE 20
STUDENTS
Payments which a student or business apprentice who is or was immediately before
visiting a Contracting State a resident of the other Contracting State and who is present
in the first-mentioned State solely for the purpose of his education or training receives
for the purpose of his maintenance, education or training shall not be taxed in that
State, provided that such payments arise from sources outside that State.
ARTICLE 21
OTHER INCOME
1. Items of income of a resident of a Contracting State, wherever arising, not dealt
with in the foregoing Articles of this Convention shall be taxable only in that State.
2. The provisions of paragraph 1 shall not apply to income, other than income from
immovable property as defined in paragraph 2 of Article 6, if the recipient of such
income, being a resident of a Contracting State, carries on business in the other
Contracting State through a permanent establishment situated therein and the right or
property in respect of which the income is paid is effectively connected with such
permanent establishment. In such case the provisions of Article 7 shall apply.