Government service taxation: source state taxation with limited residence and nationality exceptions for remuneration and pensions.

Salaries, wages and similar remuneration paid by a Contracting State or its sub-division for services to that State are 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 render the services. Pensions paid by or from funds of a Contracting State for such services are taxable only in that State, except where the individual is both resident and national of the other Contracting State. Articles 16-19 apply where services are connected with a business carried on by the State or its sub-division.

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