Government service taxation: State-paid salaries and pensions are generally taxable in the paying state, with limited residence exceptions. Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services to that State are taxable only in that State, except when 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 those services. Pensions paid by or from State funds are generally taxable only in the paying State, except where the recipient is both resident and national of the other State. Employment- and service-related remuneration tied to State-run business activities is subject to the treaty's rules on employment income and related provisions.
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: State-paid salaries and pensions are generally taxable in the paying state, with limited residence exceptions.
Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services to that State are taxable only in that State, except when 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 those services. Pensions paid by or from State funds are generally taxable only in the paying State, except where the recipient is both resident and national of the other State. Employment- and service-related remuneration tied to State-run business activities is subject to the treaty's rules on employment income and related provisions.
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