Government service taxation: remuneration generally taxable only in the paying state, with residence and nationality exceptions. Remuneration paid by a Contracting State or its subdivisions for services rendered to that State is generally taxable only in the paying State, except when 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 services; then taxation is in the State of residence. Pensions paid by or from funds of a Contracting State are similarly taxable only in the paying State, except where the recipient is both resident and national of the other State. Articles 15-18 govern remuneration and pensions for services connected with a State-operated business.
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: remuneration generally taxable only in the paying state, with residence and nationality exceptions.
Remuneration paid by a Contracting State or its subdivisions for services rendered to that State is generally taxable only in the paying State, except when 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 services; then taxation is in the State of residence. Pensions paid by or from funds of a Contracting State are similarly taxable only in the paying State, except where the recipient is both resident and national of the other State. Articles 15-18 govern remuneration and pensions for services connected with a State-operated business.
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