Government remuneration under tax treaty rules allocates taxing rights for salaries, pensions, and business-connected payments. Government remuneration paid by a Contracting State, its political subdivisions, or local authorities for services rendered to that government is taxable only in that State, subject to an exception where the services are rendered in the other Contracting State and the recipient is a resident and national of that other State, or did not become resident there solely to perform the services. Pensions and similar remuneration for such services follow a corresponding source-based rule, with an exception for a resident and national of the other Contracting State. Remuneration connected with a business carried on by a government entity is governed by the relevant treaty articles.
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 remuneration under tax treaty rules allocates taxing rights for salaries, pensions, and business-connected payments.
Government remuneration paid by a Contracting State, its political subdivisions, or local authorities for services rendered to that government is taxable only in that State, subject to an exception where the services are rendered in the other Contracting State and the recipient is a resident and national of that other State, or did not become resident there solely to perform the services. Pensions and similar remuneration for such services follow a corresponding source-based rule, with an exception for a resident and national of the other Contracting State. Remuneration connected with a business carried on by a government entity is governed by the relevant treaty articles.
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