Government service taxation: allocation of taxing rights between source State and residence State for salaries and pensions. Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are generally taxable only in the paying State, except when services are performed 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. Pensions paid by or from funds of a Contracting State for such services are taxable only in the paying State unless the individual is both resident and a national of the other State; remuneration and pensions connected with a State-run business follow the Articles on employment and personal services.
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: allocation of taxing rights between source State and residence State for salaries and pensions.
Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are generally taxable only in the paying State, except when services are performed 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. Pensions paid by or from funds of a Contracting State for such services are taxable only in the paying State unless the individual is both resident and a national of the other State; remuneration and pensions connected with a State-run business follow the Articles on employment and personal services.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
AI OCR ✕
of 
TaxTMI 
TaxTMI 
