Government service remuneration taxed in the paying state, with narrow residence and nationality exceptions for services rendered abroad. Remuneration other than pensions paid by a Contracting State or its subdivisions for services rendered to that State is taxable only in that State, except where services are performed in the other Contracting State and the individual resident there is a national or did not become resident solely to render the services, in which case the remuneration is taxable only in the other Contracting State; similarly, pensions paid by a Contracting State are taxable only in that State except when the recipient is both resident and national of the other Contracting State.
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 taxed in the paying state, with narrow residence and nationality exceptions for services rendered abroad.
Remuneration other than pensions paid by a Contracting State or its subdivisions for services rendered to that State is taxable only in that State, except where services are performed in the other Contracting State and the individual resident there is a national or did not become resident solely to render the services, in which case the remuneration is taxable only in the other Contracting State; similarly, pensions paid by a Contracting State are taxable only in that State except when the recipient is both resident and national of the other Contracting State.
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