Taxation of government service remuneration: allocation to the paying State with limited residency-based exceptions. Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are generally taxable only in that State, except where the services are rendered 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; similar allocation rules apply to pensions paid by a Contracting State, which are taxable only in the other State if the recipient is both resident and national of that State. Remuneration and pensions related to a State's business activities 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.
Taxation of government service remuneration: allocation to the paying State with limited residency-based exceptions.
Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are generally taxable only in that State, except where the services are rendered 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; similar allocation rules apply to pensions paid by a Contracting State, which are taxable only in the other State if the recipient is both resident and national of that State. Remuneration and pensions related to a State's business activities are governed by Articles 15-18.
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