Government service taxation: payor State generally taxes remuneration unless resident national conditions shift taxation to the other State. Government service remuneration paid by a Contracting State or its subdivisions is generally taxable only in the paying State, but if services are rendered in the other Contracting State and the individual is a resident who is a national of that State or did not become a resident solely to render services, taxation is confined to that other State. Pensions from state funds are taxable in the paying State except where the recipient is both resident and national of the other State. Remuneration and pensions tied to a State's business activities are subject to 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: payor State generally taxes remuneration unless resident national conditions shift taxation to the other State.
Government service remuneration paid by a Contracting State or its subdivisions is generally taxable only in the paying State, but if services are rendered in the other Contracting State and the individual is a resident who is a national of that State or did not become a resident solely to render services, taxation is confined to that other State. Pensions from state funds are taxable in the paying State except where the recipient is both resident and national of the other State. Remuneration and pensions tied to a State's business activities are subject to Articles 16-19.
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