Taxation of government remuneration: state-paid salaries and pensions generally taxed only in the paying state, with residency-based exceptions.

Article 19 provides that salaries, wages and similar remuneration paid by a Contracting State or its subdivisions for services to that State are taxable only in that State, except when services are rendered in the other Contracting State and the individual is a resident who is either a national of that State or did not become resident solely to render the services. Pensions paid by or from funds of the paying State are taxable only in that State, except when the recipient is both resident and a national of the other State. Articles 15, 16 and 18 apply to state-conducted business services.

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