Government service taxation: salaries and pensions generally taxable only in the paying state, subject to residency and location exceptions. Article 19 allocates taxing rights over salaries, wages and similar remuneration and pensions paid by a Contracting State or its subdivisions: such remuneration is taxable only in the paying State unless 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 the paying State are taxable only in that State except where the recipient is both resident and national of the other State. Articles 15-18 apply where services relate to a business carried on by the State or its subdivisions.
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, subject to residency and location exceptions.
Article 19 allocates taxing rights over salaries, wages and similar remuneration and pensions paid by a Contracting State or its subdivisions: such remuneration is taxable only in the paying State unless 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 the paying State are taxable only in that State except where the recipient is both resident and national of the other State. Articles 15-18 apply where services relate to a business carried on by the State or its subdivisions.
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