Governmental remuneration taxation limited to paying state, with residence and nationality exceptions shifting taxation to the other state.

Remuneration and pensions paid by a Contracting State or its sub divisions for governmental functions are generally taxable only in that State, except where services are rendered in the other Contracting State and the individual is a resident who is a national or did not become resident solely to perform the services; similarly, pensions from government funds are taxable only in the paying State unless the recipient is both resident and national of the other State. Remuneration and pensions tied to government business activities are governed by the rules applicable to business profits and related articles.

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