Government service remuneration rules: primary taxation in the paying state, residency and nationality create exceptions. Remuneration other than pensions paid by a Contracting State or its subdivisions for governmental services is taxable only in the paying State, except when services are performed in the other State and the individual is a resident there who is a national or did not become resident solely to render the services, in which case taxation is only in the State of residence. Pensions paid by a Contracting State or from its funds are taxable only in the paying State, except where the recipient is both resident and national of the other State, making the other State the taxing State. Articles 16-18 apply where services relate to 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.
Government service remuneration rules: primary taxation in the paying state, residency and nationality create exceptions.
Remuneration other than pensions paid by a Contracting State or its subdivisions for governmental services is taxable only in the paying State, except when services are performed in the other State and the individual is a resident there who is a national or did not become resident solely to render the services, in which case taxation is only in the State of residence. Pensions paid by a Contracting State or from its funds are taxable only in the paying State, except where the recipient is both resident and national of the other State, making the other State the taxing State. Articles 16-18 apply where services relate to a business carried on by the State.
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