Government service remuneration taxed in paying state, with residency-based exceptions when services are rendered abroad. Remuneration paid by a Contracting State or its subdivisions 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 either a national of that State or did not become a resident solely to render the services; in that case taxability lies only in the State of performance. Pensions from state funds follow the same rule, but are taxable only in the other State where the recipient is both resident and national. Payments connected with a State-run business are governed by Articles 15-18.
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 taxed in paying state, with residency-based exceptions when services are rendered abroad.
Remuneration paid by a Contracting State or its subdivisions 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 either a national of that State or did not become a resident solely to render the services; in that case taxability lies only in the State of performance. Pensions from state funds follow the same rule, but are taxable only in the other State where the recipient is both resident and national. Payments connected with a State-run business are governed by Articles 15-18.
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