Remuneration from public funds generally exempt from source-state tax unless paid to that state's citizen or for profit-making activities.

Remuneration paid from a Contracting Party's public funds for services rendered in the other Contracting Party is exempt from taxation in the source state unless the payment is made to a citizen of that source state; the exemption does not apply to payments for services connected with profit-making trade or business carried on by a Contracting Party or its political subdivisions and expressly covers specified public entities such as central banks, state railways and postal administrations.

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