Government service remuneration taxed in the paying state, with residence and national exceptions when services rendered abroad. Remuneration paid by a Contracting State or its political sub divisions/local authorities for services to that State is taxable only in the paying State, except where services are performed in the other Contracting State and the individual is a resident there who is a national or did not become resident solely to render the services; the rule also covers members of permanent delegations. Pensions from state funds are taxable only in the paying State, except when the recipient is both resident and national of the other State. Articles 15-18 apply where services relate to a business carried on by the State or its subdivisions.
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 taxed in the paying state, with residence and national exceptions when services rendered abroad.
Remuneration paid by a Contracting State or its political sub divisions/local authorities for services to that State is taxable only in the paying State, except where services are performed in the other Contracting State and the individual is a resident there who is a national or did not become resident solely to render the services; the rule also covers members of permanent delegations. Pensions from state funds are taxable only in the paying State, except when the recipient is both resident and national of the other State. Articles 15-18 apply where services relate to a business carried on by the State or its subdivisions.
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