Government service remuneration taxable in the paying State, with residence-based exceptions allowing taxation in the resident State.

Remuneration paid by a Contracting State or its subdivisions for governmental services is taxable only in the paying State, except where services are rendered in the other State and the individual is a resident who is a national or who did not become resident solely to perform the services. Pensions paid by, or from funds contributed to by, a Contracting State are taxable only in the paying State, except where the recipient is both resident and national of the other State; payments related to a State's business activities fall under Articles 15-18.

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