Taxation of government service remuneration: residency and nationality determine which state may tax pay 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 that State, except where services are performed in the other Contracting State by a resident who is a national or who did not become resident solely to render the services. Pensions paid by or out of funds created by a Contracting State, its subdivisions or local authorities are taxable only in that State, except when the individual is both resident and national of the other Contracting State. Articles 15-17 apply where services are in connection with 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.
Taxation of government service remuneration: residency and nationality determine which state may tax pay 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 that State, except where services are performed in the other Contracting State by a resident who is a national or who did not become resident solely to render the services. Pensions paid by or out of funds created by a Contracting State, its subdivisions or local authorities are taxable only in that State, except when the individual is both resident and national of the other Contracting State. Articles 15-17 apply where services are in connection with a business carried on by the State.
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