Government service taxation: State-paid remuneration and pensions generally taxable in the paying State, with residence and nationality exceptions.

Article 19 provides that salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are taxable only in the paying State, except when services are rendered in the other Contracting State and the individual is a resident who is a national or did not become resident solely to render services. Pensions paid by or from State funds are likewise taxable only in the paying State, with an exception when the individual is both resident and national of the other State. Articles 15-18 apply to payments tied to a State's business activities.

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