Government service taxation: residency and nationality determine whether remuneration and pensions are taxed in source or residence state.

Article 19 allocates taxing rights over remuneration and pensions paid by a State or its political sub divisions and local authorities for services rendered to that State. Remuneration may be taxed by the paying State unless services are rendered in the other State and the individual is a resident who is a national of that State or did not become resident solely to render the services. Pensions may be taxed by the paying State unless the individual is both resident in and a national of the other State. Articles 15, 16 and 18 apply to services connected with a State business.

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