Government service taxation: paying State generally taxes public service pay, with residence exceptions for service-state taxation. Article 19 provides that salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered 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 there who is a national or did not become resident solely to render those services, in which case taxation lies only in the State of service. Pensions paid by a Contracting State or from its funds are normally taxable only in the paying State, except if the pensioner is both resident and national of the other State. Articles 15-18 apply to payments connected with a business carried on by a Contracting State or its subdivisions.
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: paying State generally taxes public service pay, with residence exceptions for service-state taxation.
Article 19 provides that salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered 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 there who is a national or did not become resident solely to render those services, in which case taxation lies only in the State of service. Pensions paid by a Contracting State or from its funds are normally taxable only in the paying State, except if the pensioner is both resident and national of the other State. Articles 15-18 apply to payments connected with a business carried on by a Contracting State or its subdivisions.
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