Taxation of government salaries: paying State generally taxes remuneration, with residence-based exceptions for service location. Remuneration paid by a Contracting State to individuals for services rendered to that State is taxable only in the paying State, except where services are rendered in the other Contracting State and the individual is a resident who is either a national or did not become resident solely to render the services; in that situation the other State taxes the remuneration. Pensions paid by a Contracting State are taxable in the paying State unless the recipient is both resident and national of the other State, in which case that other State taxes the pension. Compensation connected with a State business is 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.
Taxation of government salaries: paying State generally taxes remuneration, with residence-based exceptions for service location.
Remuneration paid by a Contracting State to individuals for services rendered to that State is taxable only in the paying State, except where services are rendered in the other Contracting State and the individual is a resident who is either a national or did not become resident solely to render the services; in that situation the other State taxes the remuneration. Pensions paid by a Contracting State are taxable in the paying State unless the recipient is both resident and national of the other State, in which case that other State taxes the pension. Compensation connected with a State business is governed by Articles 15-18.
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