その他令和7年7月4日
租税条約の条文（第16条〜第19条）
号外p.31
号外p.31
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ARTICLE 16
ENTERTAINERS AND SPORTSPERSONS
1. Notwithstanding the provisions of Article 14, income derived by a resident of a
Contracting State as an entertainer, such as a theatre, motion picture, radio or television
artiste, or a musician, or as a sportsperson, from that resident's personal activities as such
exercised in the other Contracting State, may be taxed in that other Contracting State.
2. Where income in respect of personal activities exercised by an entertainer or a
sportsperson acting as such accrues not to the entertainer or sportsperson but to another
person, that income may, notwithstanding the provisions of Article 14, be taxed in the
Contracting State in which the activities of the entertainer or sportsperson are exercised.
ARTICLE 17
PENSIONS
Subject to the provisions of paragraph 2 of Article 18, pensions and other similar
remuneration beneficially owned by a resident of a Contracting State shall be taxable only
in that Contracting State.
ARTICLE 18
GOVERNMENT SERVICE
1. (a) Salaries, wages and other similar remuneration paid by a Contracting State
or a political subdivision or local authority thereof to an individual in
respect of services rendered to that Contracting State or political
subdivision or local authority shall be taxable only in that Contracting
State.
(b) However, such salaries, wages and other similar remuneration shall be
taxable only in the other Contracting State if the services are rendered ir
that other Contracting State and the individual is a resident of that other
Contracting State who:
(i) is a national of that other Contracting State; or
(ii) did not become a resident of that other Contracting State solely for
the purpose of rendering the services
2. (a) Notwithstanding the provisions of paragraph 1, pensions and other similar
remuneration paid by, or out of funds which are created by or to which
contributions are made by, a Contracting State or a political subdivision or
local authority thereof to an individual in respect of services rendered to
that Contracting State or political subdivision or local authority shall be
taxable only in that Contracting 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 other Contracting State.
3. The provisions of Articles 14,15, 16 and 17 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 local
authority thereof.
ARTICLE 19
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 Contracting 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 Contracting State, provided that such payments arise from sources outside
that Contracting State. In the case of a business apprentice, the exemption provided by
this Article shall apply only for a period not exceeding one year from the date on which
he first begins his training in that Contracting State.
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