Government service taxation: state-paid remuneration is taxable only in the paying state, with limited residency exceptions. Salaries, wages and similar remuneration paid by a Contracting State or its subdivisions 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 perform the services. Pensions paid by or from state-created funds for such services are likewise taxable only in that State, except where the individual is both resident and national of the other State. Articles 15-18 govern amounts tied to state-conducted businesses.
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 remuneration is taxable only in the paying state, with limited residency exceptions.
Salaries, wages and similar remuneration paid by a Contracting State or its subdivisions 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 perform the services. Pensions paid by or from state-created funds for such services are likewise taxable only in that State, except where the individual is both resident and national of the other State. Articles 15-18 govern amounts tied to state-conducted businesses.
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