Government service taxation: pay and pensions generally taxed in the paying state, with residency exceptions. Remuneration (other than pensions) paid by a Contracting State or its political sub-divisions or local authorities for services to that State is taxable only in the paying State, except when services are rendered in the other Contracting State and the individual is a resident there who is a national or did not become resident solely to render the services; in that case the other State taxes the remuneration. Pensions paid by or from funds of the paying State are taxable only in that State, except where the recipient is both resident and national of the other State. Articles 15, 16 and 18 govern amounts connected to State-run business activities.
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 generally taxed in the paying state, with residency exceptions.
Remuneration (other than pensions) paid by a Contracting State or its political sub-divisions or local authorities for services to that State is taxable only in the paying State, except when services are rendered in the other Contracting State and the individual is a resident there who is a national or did not become resident solely to render the services; in that case the other State taxes the remuneration. Pensions paid by or from funds of the paying State are taxable only in that State, except where the recipient is both resident and national of the other State. Articles 15, 16 and 18 govern amounts connected to State-run business activities.
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