Taxation of government remuneration: generally taxable in the paying state, with residence and nationality exceptions.

Remuneration paid by a Contracting State or its subdivisions for services rendered to that State is generally taxable only in that State, except where services are rendered in the other Contracting State and the individual is a resident there who is a national or did not become resident solely to render the services; in that case taxation is confined to the State where services are rendered. Pensions paid by or from funds created by the paying State for such services are generally taxable only in the paying State, except when the pensioner is both resident and a national of the other State, in which case taxation lies only in that other State. Business-related remuneration and pensions follow the treaty rules for business income.

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