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Government service remuneration generally taxable in the paying State, with residency and nationality exceptions determining alternative taxation. Remuneration for services rendered to a Contracting State, its political subdivisions, local authorities or statutory bodies is taxable only in that paying State, except where services are performed in the other Contracting State and the individual is a resident who is a national of that State or did not become resident solely to perform the services. Pensions paid by or from funds created by such public employers are taxable only in the paying State, except where the recipient is both resident and a national of the other State. Articles 16-19 govern payments connected with a business carried on by such public entities.
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Provisions expressly mentioned in the judgment/order text.
Government service remuneration generally taxable in the paying State, with residency and nationality exceptions determining alternative taxation.
Remuneration for services rendered to a Contracting State, its political subdivisions, local authorities or statutory bodies is taxable only in that paying State, except where services are performed in the other Contracting State and the individual is a resident who is a national of that State or did not become resident solely to perform the services. Pensions paid by or from funds created by such public employers are taxable only in the paying State, except where the recipient is both resident and a national of the other State. Articles 16-19 govern payments connected with a business carried on by such public entities.
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