Government service remuneration is taxable in the paying State, with residency-based exceptions and parallel pension rules. Remuneration paid by a Contracting State or its political subdivisions for services rendered is generally taxable only in that State, but becomes taxable only in the other State if the services are performed there and the individual is a resident who is either a national of that State or did not become resident solely to render the services. Pensions paid by or from funds created by a Contracting State for such services are also taxable only in that State, except where the pensioner is both resident and national of the other State. Articles 15, 16 and 19 govern amounts connected with a business carried on by the 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 remuneration is taxable in the paying State, with residency-based exceptions and parallel pension rules.
Remuneration paid by a Contracting State or its political subdivisions for services rendered is generally taxable only in that State, but becomes taxable only in the other State if the services are performed there and the individual is a resident who is either a national of that State or did not become resident solely to render the services. Pensions paid by or from funds created by a Contracting State for such services are also taxable only in that State, except where the pensioner is both resident and national of the other State. Articles 15, 16 and 19 govern amounts connected with a business carried on by the State.
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