Taxation of government remuneration and pensions: paying state generally retains taxing right, with narrow residence exceptions. Article 19 provides that remuneration (other than pensions) and pensions paid by a Contracting State or its subdivisions for services rendered to that State are generally taxable only in the paying State, with exceptions: remuneration is taxable only in the other State when services are rendered there and the individual is a resident who is a national or did not become resident solely to render services; pensions are taxable only in the other State when the individual is both resident and national there. Business-connected services follow the treaty rules for business 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.
Taxation of government remuneration and pensions: paying state generally retains taxing right, with narrow residence exceptions.
Article 19 provides that remuneration (other than pensions) and pensions paid by a Contracting State or its subdivisions for services rendered to that State are generally taxable only in the paying State, with exceptions: remuneration is taxable only in the other State when services are rendered there and the individual is a resident who is a national or did not become resident solely to render services; pensions are taxable only in the other State when the individual is both resident and national there. Business-connected services follow the treaty rules for business income.
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