Government service remuneration and pensions: primary taxation by the paying state, with residence-based exceptions. Allocation of taxing rights for government-service payments assigns primary taxation to the paying Contracting State for remuneration (other than pensions) and for pensions paid from state-created funds. Exceptions permit the other State to tax remuneration when services are performed there and the individual is a resident who is a national or did not become resident solely to render services, and permit the other State to tax pensions when the pensioner is both resident and national of that State. Payments linked to a State-run business follow the treaty rules for business and employment income.
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 remuneration and pensions: primary taxation by the paying state, with residence-based exceptions.
Allocation of taxing rights for government-service payments assigns primary taxation to the paying Contracting State for remuneration (other than pensions) and for pensions paid from state-created funds. Exceptions permit the other State to tax remuneration when services are performed there and the individual is a resident who is a national or did not become resident solely to render services, and permit the other State to tax pensions when the pensioner is both resident and national of that State. Payments linked to a State-run business follow the treaty rules for business and employment income.
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