Government service remuneration rules allocate primary taxing rights to the paying State with narrow residency and nationality exceptions. Remuneration (other than pension) paid by a Contracting State or its subdivisions for services rendered to that State is generally taxable only in that State, except where the 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. Pensions paid by or from funds of a Contracting State for services to that State are generally taxable only in that State, except where the recipient is both resident and national of the other Contracting State. Remuneration and pensions tied to a State's business are governed by Articles 15-17.
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 rules allocate primary taxing rights to the paying State with narrow residency and nationality exceptions.
Remuneration (other than pension) paid by a Contracting State or its subdivisions for services rendered to that State is generally taxable only in that State, except where the 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. Pensions paid by or from funds of a Contracting State for services to that State are generally taxable only in that State, except where the recipient is both resident and national of the other Contracting State. Remuneration and pensions tied to a State's business are governed by Articles 15-17.
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