Taxation of government service income: source-state rule with residence-based exception for nationals and established residents. Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions, local authorities or statutory bodies for services rendered to that authority are taxable only in the paying State, except where the 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; in that case taxation is limited to the State where services are rendered. Pensions paid by or from funds of a Contracting State for such services are taxable only in the paying State, except where the pensioner is both resident and national of the other State. Business connected public service income follows the treaty business income rules.
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Provisions expressly mentioned in the judgment/order text.
Taxation of government service income: source-state rule with residence-based exception for nationals and established residents.
Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions, local authorities or statutory bodies for services rendered to that authority are taxable only in the paying State, except where the 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; in that case taxation is limited to the State where services are rendered. Pensions paid by or from funds of a Contracting State for such services are taxable only in the paying State, except where the pensioner is both resident and national of the other State. Business connected public service income follows the treaty business income rules.
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