Government service taxation allocates pay and pensions to the paying state, with resident national exceptions for abroad services.

Remuneration (other than pensions) and pensions paid by a contracting State, its political subdivisions or local authorities are generally taxable only in the paying State. Exceptions: remuneration for services performed in the other State is taxable solely in that other State if the individual is a resident who is a national of that State or did not become resident solely to perform the services; pensions are taxable only in the other State where the individual is both resident and national of that State. Payments connected with a State's business are governed by Articles 16, 17 and 19.

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