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.
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.
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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