Government service taxation: paying State retains primary taxing rights, with residency-based exceptions for service income and pensions. Remuneration paid by a Contracting State or its subdivisions for services to that State is taxable only in that State, except where services are performed in the other State and the individual is resident there and either a national or not resident solely to render the services. Pensions from a Contracting State are taxable in the paying State unless the pensioner is both resident and a national of the other State. Payments related to services in connection with a State's business are subject to the treaty provisions on business-related remuneration and pensions.
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 retains primary taxing rights, with residency-based exceptions for service income and pensions.
Remuneration paid by a Contracting State or its subdivisions for services to that State is taxable only in that State, except where services are performed in the other State and the individual is resident there and either a national or not resident solely to render the services. Pensions from a Contracting State are taxable in the paying State unless the pensioner is both resident and a national of the other State. Payments related to services in connection with a State's business are subject to the treaty provisions on business-related remuneration and pensions.
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