Government service taxation: residency and nationality determine which Contracting State may tax remuneration and pensions. Remuneration (other than pensions) paid by a Contracting State, its political subdivisions or local authorities for services rendered to that State is taxable only in the paying State, except where services are performed in the other Contracting State and the individual is a resident who is a national of that State or did not become resident solely to render the services; analogous rules allocate taxation of pensions paid by or from State funds to the paying State unless the recipient is both resident and national of the other Contracting State. Articles 15, 16 and 19 apply where services relate to a business carried on by the State.
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.
Government service taxation: residency and nationality determine which Contracting State may tax remuneration and pensions.
Remuneration (other than pensions) paid by a Contracting State, its political subdivisions or local authorities for services rendered to that State is taxable only in the paying State, except where services are performed in the other Contracting State and the individual is a resident who is a national of that State or did not become resident solely to render the services; analogous rules allocate taxation of pensions paid by or from State funds to the paying State unless the recipient is both resident and national of the other Contracting State. Articles 15, 16 and 19 apply where services relate to a business carried on by the State.
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