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Government service taxation: salaries and pensions generally taxable in the paying State, with limited residence exceptions. Article 19 treats remuneration for Government Service as taxable only in the paying Contracting State, except where services are rendered in the other State and the individual is a resident who is either a national or did not become resident solely to perform the services. Pensions from State funds are similarly taxable only in the paying State, unless the recipient is both resident and national of the other State or the pension is exempt in the paying State. Services connected with a State's business are subject to the treaty rules applicable to employment and related services.
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Provisions expressly mentioned in the judgment/order text.
Government service taxation: salaries and pensions generally taxable in the paying State, with limited residence exceptions.
Article 19 treats remuneration for Government Service as taxable only in the paying Contracting State, except where services are rendered in the other State and the individual is a resident who is either a national or did not become resident solely to perform the services. Pensions from State funds are similarly taxable only in the paying State, unless the recipient is both resident and national of the other State or the pension is exempt in the paying State. Services connected with a State's business are subject to the treaty rules applicable to employment and related services.
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