Government service remuneration and pensions: paying state generally has the exclusive taxing right, subject to residence and nationality exceptions. Remuneration paid by a Contracting State or its political sub-divisions for services rendered to that State is generally 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 or did not become resident solely to render the services; in that case taxation is in the State of residence. Pensions paid by or from funds of a Contracting State are taxable only in the paying State, except when the recipient is both resident and national of the other Contracting State, in which case taxation is in that other State. Remuneration and pensions connected with a State's business are governed by the treaty provisions applicable to employment and related income.
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Provisions expressly mentioned in the judgment/order text.
Government service remuneration and pensions: paying state generally has the exclusive taxing right, subject to residence and nationality exceptions.
Remuneration paid by a Contracting State or its political sub-divisions for services rendered to that State is generally 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 or did not become resident solely to render the services; in that case taxation is in the State of residence. Pensions paid by or from funds of a Contracting State are taxable only in the paying State, except when the recipient is both resident and national of the other Contracting State, in which case taxation is in that other State. Remuneration and pensions connected with a State's business are governed by the treaty provisions applicable to employment and related income.
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