Government service taxation limits taxable rights to the paying State, with residence and nationality exceptions for salaries and pensions. Salaries, wages and similar remuneration paid by a Contracting State or its subdivisions for services to that State are taxable only in the paying State, except when services are rendered in the other Contracting State and the individual resident is either a national or did not become resident solely to render the services. Pensions paid by or from funds of a Contracting State are generally taxable only in the paying State, except where the pensioner 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 taxation limits taxable rights to the paying State, with residence and nationality exceptions for salaries and pensions.
Salaries, wages and similar remuneration paid by a Contracting State or its subdivisions for services to that State are taxable only in the paying State, except when services are rendered in the other Contracting State and the individual resident is either a national or did not become resident solely to render the services. Pensions paid by or from funds of a Contracting State are generally taxable only in the paying State, except where the pensioner is both resident and national of the other Contracting State.
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