Government service taxation: salaries and pensions generally taxable only in the paying State, with specific residency exceptions. Remuneration paid by a Contracting State or its sub divisions for services rendered to that State is generally taxable only in the paying State, except when services are rendered in the other 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 are taxable only in the paying State, except when the pensioner is both resident and national of the other State. Employment- and business-connected services are governed by the treaty provisions for those income categories.
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.
Government service taxation: salaries and pensions generally taxable only in the paying State, with specific residency exceptions.
Remuneration paid by a Contracting State or its sub divisions for services rendered to that State is generally taxable only in the paying State, except when services are rendered in the other 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 are taxable only in the paying State, except when the pensioner is both resident and national of the other State. Employment- and business-connected services are governed by the treaty provisions for those income categories.
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