Government service taxation limits pay and pensions to the paying State unless rendered abroad by a resident national. Remuneration paid by a Contracting State or its subdivisions for services rendered to that State is generally taxable only in that State, except where services are performed 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; the rule also covers members of permanent delegations. Pensions paid by a Contracting State are taxable only in that State, subject to an exception where the recipient is both resident and national of the other Contracting State; remuneration and pensions tied to a State's business are governed by Articles 15-18.
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 pay and pensions to the paying State unless rendered abroad by a resident national.
Remuneration paid by a Contracting State or its subdivisions for services rendered to that State is generally taxable only in that State, except where services are performed 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; the rule also covers members of permanent delegations. Pensions paid by a Contracting State are taxable only in that State, subject to an exception where the recipient is both resident and national of the other Contracting State; remuneration and pensions tied to a State's business are governed by Articles 15-18.
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