Government remuneration and pension taxation: source-state rule with residency exceptions shifting tax to the resident State. Remuneration paid by a Contracting State or its political subdivisions for services to that State is taxable only in the paying State, except where services are performed in the other State and the individual is a resident who is a national or did not become resident solely to render services. Pensions paid by or from funds of a Contracting State for services are taxable only in the paying State, except when the pensioner is both resident and national of the other State. Business-related services fall under the treaty provisions for business income and related categories.
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 remuneration and pension taxation: source-state rule with residency exceptions shifting tax to the resident State.
Remuneration paid by a Contracting State or its political subdivisions for services to that State is taxable only in the paying State, except where services are performed in the other State and the individual is a resident who is a national or did not become resident solely to render services. Pensions paid by or from funds of a Contracting State for services are taxable only in the paying State, except when the pensioner is both resident and national of the other State. Business-related services fall under the treaty provisions for business income and related categories.
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