Government service remuneration taxable primarily in paying State, with residency and nationality exceptions determining alternate taxation. Remuneration paid by a Contracting State, its political subdivisions or local authorities for services rendered to that State is generally taxable only in the paying State, except where services are rendered in the other Contracting State by a resident who is a national or did not become resident solely to render services, in which case taxation lies in the resident State; similarly, pensions paid by or from funds of a Contracting State are taxable only in the paying State unless the recipient is both resident and national of the other Contracting State, and Articles 15-18 apply to remuneration and pensions from state-run business activities.
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 primarily in paying State, with residency and nationality exceptions determining alternate taxation.
Remuneration paid by a Contracting State, its political subdivisions or local authorities for services rendered to that State is generally taxable only in the paying State, except where services are rendered in the other Contracting State by a resident who is a national or did not become resident solely to render services, in which case taxation lies in the resident State; similarly, pensions paid by or from funds of a Contracting State are taxable only in the paying State unless the recipient is both resident and national of the other Contracting State, and Articles 15-18 apply to remuneration and pensions from state-run business activities.
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