Remuneration for government service taxable only in paying state, with residency exceptions for services rendered abroad. Article 18 allocates taxing rights over remuneration and pensions for government service: remuneration paid by a Contracting State or its sub division for services rendered to that State is generally taxable only in the paying State, except where services are performed in the other 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 similarly taxable only in the paying State, except where the recipient is both resident and national of the other State. Articles 15-17 apply where services relate to a State carried business.
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Provisions expressly mentioned in the judgment/order text.
Remuneration for government service taxable only in paying state, with residency exceptions for services rendered abroad.
Article 18 allocates taxing rights over remuneration and pensions for government service: remuneration paid by a Contracting State or its sub division for services rendered to that State is generally taxable only in the paying State, except where services are performed in the other 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 similarly taxable only in the paying State, except where the recipient is both resident and national of the other State. Articles 15-17 apply where services relate to a State carried business.
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