ARTICLE 14 　　　　　　　　　　Independent Personal Services 　　1. Income derived by an individual who is a resident of a Contracting State in respect of professional services or other activities of an independent character shall be taxable only in that State unless such services are performed in the other Contracting State and he has a fixed base regularly available to him in the other Contracting State for the purpose of performing his activities. In such case, the income may be taxed in the other State, but only so much of it as is attributable to that fixed base. For this purpose, where an individual who is a resident of a Contracting State stays in the other Contracting State for a period or periods exceeding in the aggregate 183 days in any twelve-month period commencing or ending in the taxable year concerned, he shall be deemed to have a fixed base regularly available to him in that other State and the income that is derived from his activities referred to in the first sentence of this paragraph shall be attributable to that fixed base. 　　2. For the purposes of paragraph 1, the income that is taxable in the other Contracting State shall be determined in the same way as income of a resident of that other State derived in respect of professional services or other activities of an independent character. However, nothing in this paragraph shall be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities that it grants to its own residents. 　　3. The term "professional services" includes especially independent scientific, literary, artistic, educational or teaching activities as well as the independent activities of physicians, lawyers, engineers, architects, dentists and accountants. ARTICLE 15 Dependent Personal Services 　　1. Subject to the provisions of Articles 16 (Directors' Fees), 18 (Pensions, Social Security, Annuities, Alimony, and Child Support), 19 (Government Service) and 20 (Students, Trainees and Researchers), salaries, wages and other remuneration derived by a resident of a Contracting 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, 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 any twelve-month period commencing or ending in the taxable 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 borne by a permanent establishment or a fixed base which the employer has in the other State. 　　3. Notwithstanding the preceding provisions of this Article, remuneration in respect of an employment as a member of the regular complement of a ship or aircraft operated by an enterprise of a Contracting State in international traffic may be taxed in that Contracting State. ARTICLE 16 Directors' Fees 　　Directors' fees and other compensation derived by a resident of a Contracting State in his capacity as a member of the board of directors or any similar organ of a company that is a resident of the other Contracting State may be taxed in that other State. ARTICLE 17 Artistes and Sportsmen 　　1. Notwithstanding the provisions of Articles 14 (Independent Personal Services) and 15 (Dependent Personal Services), income derived by a resident of a Contracting State as an entertainer, such as a theater, motion picture, radio or television artiste, or a musician, or as a sportsman, from his personal activities as such exercised in the other Contracting State, may be taxed in that other State, except where the amount of the gross receipts derived by such entertainer or sportsman, including expenses reimbursed to him or borne on his behalf, from such activities does not exceed twenty thousand United States dollars ($20,000) or its equivalent in Latvian lats for the taxable year concerned. 　　2. Where income in respect of activities exercised by an entertainer or a sportsman in his capacity as such accrues not to the entertainer or sportsman but to another person, that income of that other person may, notwithstanding the provisions of Articles 7 (Business Profits), 14 (Independent Personal Services) and 15 (Dependent Personal Services), be taxed in the Contracting State in which the activities of the entertainer or sportsman are exercised, unless it is established that neither the entertainer or sportsman nor persons related thereto participate directly or indirectly in the profits of that other person in any manner, including the receipt of deferred remuneration, bonuses, fees, dividends, partnership distributions, or other distributions. 　　3. The provisions of paragraphs 1 and 2 shall not apply to income derived from activities exercised in a Contracting State by a resident of the other Contracting State as an entertainer or sportsman if the visit to the first-mentioned State is wholly or mainly supported by public funds of the other State or a political subdivision or local authority thereof. In such a case, the income shall be taxable only in the Contracting State of which the entertainer or sportsman is a resident. ARTICLE 18 Pensions, Social Security, Annuities, Alimony, and Child Support 　　1. Subject to the provisions of Article 19 (Government Service), pensions and other similar remuneration derived and beneficially owned by a resident of a Contracting State in consideration of past employment, whether paid periodically or as a single sum, shall be taxable only in that State, but the amount of any such pension or remuneration that would be excluded from taxable income in the other Contracting State if the recipient were a resident thereof shall be exempt from taxation in the first-mentioned State. 　　2. Notwithstanding the provisions of paragraph 1, payments made by a Contracting State under the provisions of the social security or similar legislation of that State to a resident of the other Contracting State or to a citizen of the United States shall be taxable only in the first-mentioned State. 　　3. Annuities derived and beneficially owned by a resident of a Contracting State shall be taxable only in that State. The term "annuities" as used in this paragraph means a stated sum (other than a pension) paid periodically at stated times during a specified number of years, under an obligation to make the payments in return for adequate and full consideration (other than services rendered). 　　4. Alimony paid by a resident of a Contracting State, and deductible therein, to a resident of the other Contracting State shall be taxable only in that other State. The term "alimony" as used in this paragraph means periodic payments made pursuant to a written separation agreement or a decree of divorce, separate maintenance, or compulsory support, which payments are taxable to the recipient under the laws of the State of which he is a resident. 　　5. Periodic payments, not dealt with in paragraph 4, for the support of a minor child made pursuant to a written separation agreement or a decree of divorce, separate maintenance, or compulsory support, paid by a resident of a Contracting State to a resident of the other Contracting State, shall not be taxable in that other State. ARTICLE 19 Government Service 　　1. Notwithstanding the provisions of Articles 15 (Dependent Personal Services) and 17 (Artistes and Sportsmen): 　　a) remuneration, other than a pension, paid by, or out of the public funds of a Contracting State or a political subdivision or a local authority thereof to an individual in respect of dependent personal services rendered to that State or subdivision or authority in the discharge of functions of a governmental nature shall, subject to the provisions of subparagraph b), be taxable only in that State; 　　b) such remuneration, however, shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who: 　　(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. 　　2. Subject to the provisions of paragraph 2 of Article 18 (Pensions, Social Security, Annuities, Alimony, and Child Support): 　　a) any pension paid by, or out of the public funds of 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 in the discharge of functions of a governmental nature shall, subject to the provisions of subparagraph b), be taxable only in that State; 　　b) such pension, however, shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State. ARTICLE 20 Students, Trainees and Researchers 　　1. a) An individual who is a resident of a Contracting State at the beginning of his visit to the other Contracting State and who is temporarily present in that other Contracting State for the primary purpose of: 　　(i) studying at a university or other accredited educational institution in that other Contracting State, or 　　(ii) securing training required to qualify him to practice a profession or professional speciality; or 　　(iii) studying or doing research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization; shall be exempt from tax by that other Contracting State with respect to the amounts described in subparagraph b) of this paragraph for a period not exceeding five years from the date of his arrival in that other Contracting State. 　　b) The amounts referred to in subparagraph a) of this paragraph are: 　　(i) payments from abroad, other than compensation for personal services, for the purpose of his maintenance, education, study, research, or training; 　　(ii) the grant, allowance, or award; and 　　(iii) income from personal services performed in that other Contracting State in an aggregate amount not in excess of five thousand United States dollars ($5,000) or its equivalent in Latvian lats for any taxable year. 　　2. An individual who is a resident of a Contracting State at the beginning of his visit to the other Contracting State and who is temporarily present in that other Contracting State as an employee of, or under contract with, a resident of the first-mentioned Contracting State, for the primary purpose of: 　　a) acquiring technical, professional, or business experience from a person other than that resident of the first-mentioned Contracting State, or 　　b) studying at a university or other accredited educational institution in that other Contracting State,shall be exempt from tax by that other Contracting State for a period of 12 consecutive months with respect to his income from personal services in an aggregate amount not in excess of eight thousand United States dollars ($8,000) or its equivalent in Latvian lats. 　　3. An individual who is a resident of one of the Contracting States at the time he becomes temporarily present in the other Contracting State and who is temporarily present in the other Contracting State for a period not exceeding one year, as a participant in a program sponsored by the Government of that other Contracting State, for the primary purpose of training, research, or study, shall be exempt from tax by that other Contracting State with respect to his income from personal services in respect of such training, research, or study performed in that other Contracting State in an aggregate amount not in excess of ten thousand United States dollars ($10,000) or its equivalent in Latvian lats. 　　4. This Article shall not apply to income from research if such research is undertaken not in the public interest but primarily for the private benefit of a specific person or persons. ARTICLE 21 Offshore Activities 　　1. The provisions of this Article shall apply notwithstanding the provisions of Articles 4 to 20 of this Convention. 　　2. A person who is a resident of a Contracting State and carries on activities offshore in the other Contracting State in connection with the exploration or exploitation of the sea bed and subsoil and their natural resources situated in that other State shall, subject to paragraphs 3 and 4, be deemed in relation to those activities to be carrying on business in that other State through a permanent establishment or a fixed base situated therein. 　　3. The provisions of paragraph 2 shall not apply, where the activities are carried on for a period or periods not exceeding in the aggregate 30 days in any twelve-month period. However, for the purposes of this paragraph: 　　a) activities carried on by a person who is associated with another person shall be regarded as carried on by the other person if the activities in question are substantially the same as those carried on by the first-mentioned person, except to the extent that those activities are carried on at the same time as its own activities; 　　b) a person shall be deemed to be associated with another person if one is controlled directly or indirectly by the other, or both are controlled directly or indirectly by a third person or third persons. 　　4. However, the provisions of this Article shall not apply to: 　　a) one or any combination of the activities mentioned in paragraph 4 of Article 5 (Permanent Establishment); 　　b) towing or anchor handling by ships primarily designed for that purpose and any other activities performed by such ships; or 　　c) the transport of supplies or personnel by ships or aircraft in international traffic. 　　5. a) Subject to subparagraph b) of this paragraph, salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment connected with the exploration or exploitation of the sea bed and sub-soil and their natural resources situated in the other Contracting State may, to the extent that the duties are performed offshore in that other State, be taxed in that other State. However, such remuneration shall be taxable only in the first-mentioned State if the employment is carried on offshore for an employer who is not a resident of the other State and for a period or periods not exceeding in the aggregate 30 days in any twelve month period. 　　b) salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft engaged in the transportation of supplies or personnel to a location, or between locations, where activities connected with the exploration or exploitation of the sea bed and sub-soil and their natural resources are being carried on in a Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities, may be taxed in the Contracting State of which the employer is a resident. ARTICLE 22 Other Income 　　1. Items of income beneficially owned by 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 (real) property as defined in paragraph 2 of Article 6 (Income from Immovable (Real) Property), if the beneficial owner of the income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other State independent personal services from a fixed base situated therein, and the income is attributable to such permanent establishment or fixed base. In such case the provisions of Article 7 (Business Profits) or Article 14 (Independent Personal Services), as the case may be, shall apply. ARTICLE 23 　　　　　　　　　Limitation on Benefits 　　1. A resident of a Contracting State shall be entitled to all the benefits of this Convention only if it is a "qualified resident" as defined in this Article. 　　2. A resident of a Contracting State is a qualified resident for a taxable year only if it is either: 　　a) an individual; 　　b) a Contracting State, a political subdivision or a local authority thereof, or an agency or instrumentality of such State, subdivision or authority; 　　c) a company, if: 　　(i) on at least half the days of the taxable year the beneficial owners of at least 50 percent of each class of the company's shares are qualified residents by reason of subparagraphs a), b), e), or f) of this paragraph, or U.S. citizens, provided that in the case of indirect ownership, each intermediate owner is a person entitled to benefits of the Convention under this paragraph; and 　　(ii) amounts paid or accrued by the company during its taxable year: 　　A) to persons that are neither qualified residents nor U.S. citizens, and 　　B) that are deductible for income tax purposes in the company's State of residence (but not including arm's length payments in the ordinary course of business for services or tangible property), do not exceed 50 percent of the gross income of the company for that year; 　　d) a trust or estate, if the ownership of its beneficial interests satisfies the requirement of subparagraph c)(i) and its payments to persons who are not qualified residents or U.S. citizens satisfy the requirement of subparagraph c)(ii); 　　e) a person, if: 　　(i) beneficial interests representing at least 50 percent of the value of each class of interests in that person are substantially and regularly traded on a recognized stock exchange; or 　　(ii) the direct or indirect owners of at least 50 percent of each class of interests in that person are persons entitled to benefits under clause i), provided that in the case of indirect ownership, each intermediate owner is a person entitled to benefits of the Convention under this paragraph; 　　f) a person described in subparagraph 3b) of Article 4 (Resident) provided that more than half of the beneficiaries, members or participants, if any, in such person are qualified residents; or 　　g) a United States Regulated Investment Company, or a similar entity in Latvia as may be agreed by the competent authorities of the Contracting States.