Taxation of Government Service: remuneration paid by a Contracting State generally taxable only in that State, with limited residence exceptions. Remuneration paid by a Contracting State or its sub-divisions for services rendered to that State is taxable only in the paying 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 render the services; similarly, pensions paid by or from funds of a Contracting State are taxable only in the paying State unless the pensioner is both resident and national of the other State. Remuneration and pensions connected with a State-run business follow the treaty rules for business-related income.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of Government Service: remuneration paid by a Contracting State generally taxable only in that State, with limited residence exceptions.
Remuneration paid by a Contracting State or its sub-divisions for services rendered to that State is taxable only in the paying 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 render the services; similarly, pensions paid by or from funds of a Contracting State are taxable only in the paying State unless the pensioner is both resident and national of the other State. Remuneration and pensions connected with a State-run business follow the treaty rules for business-related income.
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