Government service taxation: remuneration and pensions taxable primarily in the paying State, with residency-based exceptions. Remuneration paid by a Contracting State or its political or local subdivisions for services to that State is taxable only in that State, except when services are performed in the other Contracting State and the individual is a resident who is either a national of that State or did not become resident solely to render the services; similar rules apply to pensions, which are taxable only in the paying State unless the recipient is both a resident and national of the other State. Articles 15-18 govern remuneration and pensions tied to a business carried on by a Contracting 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 taxation: remuneration and pensions taxable primarily in the paying State, with residency-based exceptions.
Remuneration paid by a Contracting State or its political or local subdivisions for services to that State is taxable only in that State, except when services are performed in the other Contracting State and the individual is a resident who is either a national of that State or did not become resident solely to render the services; similar rules apply to pensions, which are taxable only in the paying State unless the recipient is both a resident and national of the other State. Articles 15-18 govern remuneration and pensions tied to a business carried on by a Contracting State or its subdivisions.
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