Government service remuneration taxed by the paying State, with a residence-and-nationality exception when services are abroad. Remuneration from public funds by a Contracting State or its subdivisions for services rendered to that State is taxable only in that State, except that remuneration (other than pensions) is taxable only in the other State when services are performed there by an individual who is resident and a national of that other State and not a national of the payer State. Pensions paid by or from State funds for such services are taxable only in the paying State. Remuneration and pensions connected with a State's business activity are subject to the treaty rules on business related income and services.
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 taxed by the paying State, with a residence-and-nationality exception when services are abroad.
Remuneration from public funds by a Contracting State or its subdivisions for services rendered to that State is taxable only in that State, except that remuneration (other than pensions) is taxable only in the other State when services are performed there by an individual who is resident and a national of that other State and not a national of the payer State. Pensions paid by or from State funds for such services are taxable only in the paying State. Remuneration and pensions connected with a State's business activity are subject to the treaty rules on business related income and services.
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