Taxation of government remuneration and pensions: primary taxation in the paying state with specified residency and nationality exceptions. Remuneration paid by a Contracting State, its political sub-divisions, local authorities or statutory bodies for services rendered to that State is generally 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 or did not become resident solely to render the services. Pensions paid by or from funds of such public bodies are likewise taxable only in the paying State, except where the individual is both resident and a national of the other Contracting State. Payments connected to a business of those public bodies are subject to Articles 15, 16 and 19.
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 remuneration and pensions: primary taxation in the paying state with specified residency and nationality exceptions.
Remuneration paid by a Contracting State, its political sub-divisions, local authorities or statutory bodies for services rendered to that State is generally 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 or did not become resident solely to render the services. Pensions paid by or from funds of such public bodies are likewise taxable only in the paying State, except where the individual is both resident and a national of the other Contracting State. Payments connected to a business of those public bodies are subject to Articles 15, 16 and 19.
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