Government service taxation: pay and pensions taxed in paying State unless resident national renders services abroad. Remuneration for government service paid by a Contracting State, Land, political subdivision or local authority is taxable only in the paying State, except when services are rendered in the other Contracting State by a resident who is a national or who did not become resident solely to render the services, in which case taxation is limited to the State of residence. Pensions paid for such services are taxable in the paying State, except when the recipient is both resident and a national of the other State. Remuneration and pensions connected with a State business follow Articles 15, 16 and 18; development assistance secondments are covered by the same rules.
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: pay and pensions taxed in paying State unless resident national renders services abroad.
Remuneration for government service paid by a Contracting State, Land, political subdivision or local authority is taxable only in the paying State, except when services are rendered in the other Contracting State by a resident who is a national or who did not become resident solely to render the services, in which case taxation is limited to the State of residence. Pensions paid for such services are taxable in the paying State, except when the recipient is both resident and a national of the other State. Remuneration and pensions connected with a State business follow Articles 15, 16 and 18; development assistance secondments are covered by the same rules.
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