Government service taxation: remuneration generally taxable in the paying State, with exceptions for resident nationals and pensions. Remuneration (other than a pension) paid by a Contracting State or its sub-division or local authority for services rendered to that State is taxable only in that State, except where 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. Pensions paid by, or from funds created by, 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. Articles 15, 16 and 18 apply to business-related 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 taxation: remuneration generally taxable in the paying State, with exceptions for resident nationals and pensions.
Remuneration (other than a pension) paid by a Contracting State or its sub-division or local authority for services rendered to that State is taxable only in that State, except where 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. Pensions paid by, or from funds created by, 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. Articles 15, 16 and 18 apply to business-related services.
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