Government service remuneration taxable in the paying state, with residence and nationality exceptions for in-state service. Salaries, wages and similar remuneration paid by a Contracting State or its political sub-divisions or local authorities for services rendered to that State are taxable only in the paying State, except where services are rendered in the other Contracting State and the individual is a resident who is a national of that State or did not become a resident solely to render the services; pensions paid by or from State funds are taxable only in the paying State, except where the recipient is both resident and national of the other State. Business-connected remuneration and pensions are subject to the treaty articles on business and employment.
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 taxable in the paying state, with residence and nationality exceptions for in-state service.
Salaries, wages and similar remuneration paid by a Contracting State or its political sub-divisions or local authorities for services rendered to that State are taxable only in the paying State, except where services are rendered in the other Contracting State and the individual is a resident who is a national of that State or did not become a resident solely to render the services; pensions paid by or from State funds are taxable only in the paying State, except where the recipient is both resident and national of the other State. Business-connected remuneration and pensions are subject to the treaty articles on business and employment.
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