Government remuneration tax rule: payor state retains taxing right; pensions also taxable by payor, subject to profit-making exceptions.

Remuneration (not being a pension) paid by a Contracting State to its citizen for services rendered in the other Contracting State in discharge of governmental functions is taxable only in the paying Contracting State; pensions paid by a Contracting State may be taxed in the paying Contracting State. These provisions do not apply to remuneration or pensions for services connected with any profit-making business carried on by a Government. "Government" includes State, local or statutory authorities, including the Reserve Bank of India and the Bank of Tanzania.

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