Article 19 - Government Service

Taxation of government service income: remuneration generally taxable in the paying state, with residency-based exception.

Salaries, wages and other remuneration (other than pensions) paid by a Contracting State or its subdivisions for services rendered to that State are taxable only in the paying State, except where services are performed in the other Contracting State and the individual is a resident who is a national of that other State or did not become resident solely to render the services. Remuneration for services connected with a business carried on by the State or its subdivisions is subject to the treaty provisions governing employment and business-connected income.