Government service remuneration taxable only in the payer State, with narrow exceptions for resident nationals and service purpose residents. Remuneration (other than pensions) paid by a Contracting State or its sub division to an individual for services to that State is taxable only in that State, except where 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 the services; similar rules apply to pensions, and treaty provisions governing employment and independent services govern remuneration connected with a State carried business.
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 taxable only in the payer State, with narrow exceptions for resident nationals and service purpose residents.
Remuneration (other than pensions) paid by a Contracting State or its sub division to an individual for services to that State is taxable only in that State, except where 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 the services; similar rules apply to pensions, and treaty provisions governing employment and independent services govern remuneration connected with a State carried business.
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