Article 19 - Government Service

Government service taxation limits taxing rights to the paying State, with exceptions for resident citizens and non-resident workers.

Taxation of government remuneration and pensions is generally vested in the paying State. Remuneration (excluding pensions) for governmental functions is taxable only in the paying State, unless services occur in the other State and the recipient is its resident who is a citizen or did not become resident solely to perform the services. Pensions paid by a Contracting State or from its funds are taxable only in the paying State, except where the recipient is resident and a citizen of the other State. Articles 15, 16 and 18 apply to remuneration and pensions tied to State-run business activities.