Government service remuneration: tax residence and nationality determine which State may tax pay and pension income under the treaty. Remuneration paid by a Contracting State or its subdivisions for services to that State is generally taxable only in that State, except when the services are performed in the other State and the individual is a resident who is a national or did not become resident solely to render the services. Pensions from state funds are similarly taxable only in the paying State, except when the recipient is both resident and national of the other State. Payments linked to services in connection with a State-run business are subject to the treaty rules on business income and personal services.
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: tax residence and nationality determine which State may tax pay and pension income under the treaty.
Remuneration paid by a Contracting State or its subdivisions for services to that State is generally taxable only in that State, except when the services are performed in the other State and the individual is a resident who is a national or did not become resident solely to render the services. Pensions from state funds are similarly taxable only in the paying State, except when the recipient is both resident and national of the other State. Payments linked to services in connection with a State-run business are subject to the treaty rules on business income and personal services.
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