Government service remuneration generally taxable in the paying state, with residency and nationality exceptions shifting tax to service state. Salaries, wages and similar remuneration paid by a contracting state or its subdivisions for services to that state are taxable only in the paying state, except when services are performed in the other Contracting State by a resident who is either a national or did not become resident solely to render the services, in which case taxation lies with that other state. Pensions paid by or from funds of a contracting state are taxed by the paying state unless the pensioner is both resident and national of the other Contracting State. Remuneration and pensions tied to a state-run business are governed by Articles 15-18.
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 remuneration generally taxable in the paying state, with residency and nationality exceptions shifting tax to service state.
Salaries, wages and similar remuneration paid by a contracting state or its subdivisions for services to that state are taxable only in the paying state, except when services are performed in the other Contracting State by a resident who is either a national or did not become resident solely to render the services, in which case taxation lies with that other state. Pensions paid by or from funds of a contracting state are taxed by the paying state unless the pensioner is both resident and national of the other Contracting State. Remuneration and pensions tied to a state-run business are governed by Articles 15-18.
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