Government service taxation: paying State generally taxes remuneration and pensions, with residency and nationality exceptions. Article 19 allocates taxation of remuneration and pensions from government service: salaries, wages and similar payments made by a Contracting State or its subdivisions for services rendered to that State are 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 the services. Pensions paid by a Contracting State for such services are taxable only in the paying State, except when the pensioner is both resident and national of the other State. Articles 15-18 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 taxation: paying State generally taxes remuneration and pensions, with residency and nationality exceptions.
Article 19 allocates taxation of remuneration and pensions from government service: salaries, wages and similar payments made by a Contracting State or its subdivisions for services rendered to that State are 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 the services. Pensions paid by a Contracting State for such services are taxable only in the paying State, except when the pensioner is both resident and national of the other State. Articles 15-18 apply where services relate to a business carried on by the State.
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