Government service taxation limited to the paying state, with resident citizen exceptions for services rendered abroad.

Remuneration (other than pensions) and pensions paid by a Contracting State, its political sub divisions or local authorities for governmental services are generally taxable only in the paying State. Remuneration for services performed in the other State is taxable in that other State if the recipient is a resident who is a citizen or did not become resident solely to perform the services. Pensions are taxable only in the other State if the recipient is both resident and a citizen of that other State. Treaty rules on employment and related income apply where services connect with a State carried business.

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