(1) Remunerations, excluding pensions, paid by a Contracting state or a political or administrative 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.
(2) However, such remunerations, shall be taxable only in the other Contracting State if the services are rendered in that other State and the individual is a resident of the that State:
- (i) is a national of that State; or
- (ii) did not become a resident of that State solely for the purpose of rendering the services.
(3) The provisions of Articles 15, 16, 17 and 18 shall apply to the remunerations and pensions paid in connection with a business or industrial activity carried on by a Contracting State or a political or administrative subdivision or a local authority thereof.