Government service taxation: State-paid salaries and pensions are generally taxable in the paying State, with limited residence exceptions. Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are taxable only in that State, except where services are rendered in the other Contracting State and the individual is a resident who is a national or did not become resident solely to render the services; pensions paid by or from funds of a Contracting State are taxable only in the paying State, except where the recipient is both resident and national of the other State; compensation and pensions connected to a State-run business are governed by Articles 16-19.
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: State-paid salaries and pensions are generally taxable in the paying State, with limited residence exceptions.
Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are taxable only in that State, except where services are rendered in the other Contracting State and the individual is a resident who is a national or did not become resident solely to render the services; pensions paid by or from funds of a Contracting State are taxable only in the paying State, except where the recipient is both resident and national of the other State; compensation and pensions connected to a State-run business are governed by Articles 16-19.
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