Government service taxation: salaries and pensions taxable in the paying Contracting State, with residence and nationality exceptions. Salaries, wages and similar remuneration (excluding pensions) paid by a Contracting State or its subdivisions for services rendered to that State are taxable only in that State, except where the services are rendered in the other Contracting State and the individual is a resident of that State who is a national or did not become resident solely to render the services. Pensions paid by or from funds of a Contracting State for services rendered to that State are taxable only in that State, except where the recipient is both resident and a national of the other Contracting State. Remuneration and pensions connected with a State's business activity are governed by Articles 15-18.
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 taxation: salaries and pensions taxable in the paying Contracting State, with residence and nationality exceptions.
Salaries, wages and similar remuneration (excluding pensions) paid by a Contracting State or its subdivisions for services rendered to that State are taxable only in that State, except where the services are rendered in the other Contracting State and the individual is a resident of that State who is a national or did not become resident solely to render the services. Pensions paid by or from funds of a Contracting State for services rendered to that State are taxable only in that State, except where the recipient is both resident and a national of the other Contracting State. Remuneration and pensions connected with a State's business activity are governed by Articles 15-18.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.