Government service remuneration taxed by the paying State, with residency and nationality exceptions shifting taxation to the State of performance. Remuneration for services rendered to a Contracting State or its political subdivisions is generally taxable only in the paying State; however, if services are performed in the other Contracting State and the individual is a resident who is a national or did not become resident solely to render those services, taxation shifts to the State of performance. Pensions paid by or from funds of a Contracting State are taxable in the paying State, except where the recipient is both resident and a national of the other Contracting State, in which case taxation is in that other State. Services connected with a State-run business are 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.
Government service remuneration taxed by the paying State, with residency and nationality exceptions shifting taxation to the State of performance.
Remuneration for services rendered to a Contracting State or its political subdivisions is generally taxable only in the paying State; however, if services are performed in the other Contracting State and the individual is a resident who is a national or did not become resident solely to render those services, taxation shifts to the State of performance. Pensions paid by or from funds of a Contracting State are taxable in the paying State, except where the recipient is both resident and a national of the other Contracting State, in which case taxation is in that other State. Services connected with a State-run business are governed by Articles 15-18.
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