Taxation of government remuneration: pay generally taxable in paying state, with residency and nationality exceptions. Remuneration (other than pensions) paid by a Contracting State or its subdivisions for governmental functions is taxable only in the paying State, except when services are rendered in the other State and the individual is a resident who is a national or did not become resident solely to perform the services, in which case taxation is only in that other State. Pensions paid by or from funds of a Contracting State are likewise taxable only in the paying State, except when the recipient is both resident and national of the other State. Remuneration and pensions linked to a State's business are governed by the treaty rules on business income.
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.
Taxation of government remuneration: pay generally taxable in paying state, with residency and nationality exceptions.
Remuneration (other than pensions) paid by a Contracting State or its subdivisions for governmental functions is taxable only in the paying State, except when services are rendered in the other State and the individual is a resident who is a national or did not become resident solely to perform the services, in which case taxation is only in that other State. Pensions paid by or from funds of a Contracting State are likewise taxable only in the paying State, except when the recipient is both resident and national of the other State. Remuneration and pensions linked to a State's business are governed by the treaty rules on business income.
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