Government remuneration and pension taxation: state-paid services generally taxable only in the paying state with limited residence exceptions. Remuneration (other than pensions) paid by a Contracting State or its subdivisions for services rendered to that State is taxable only in that State, except where services are rendered in the other State and the individual is resident there who is a national or did not become resident solely to perform the services. Pensions paid by or from state funds for such services are taxable only in that State, except when the individual is both resident and national of the other State. Articles 16, 17 and 19 apply to services connected with a State's business, and paragraph 1 extends to specified public financial institutions and mutually recognized organizations.
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 remuneration and pension taxation: state-paid services generally taxable only in the paying state with limited residence exceptions.
Remuneration (other than pensions) paid by a Contracting State or its subdivisions for services rendered to that State is taxable only in that State, except where services are rendered in the other State and the individual is resident there who is a national or did not become resident solely to perform the services. Pensions paid by or from state funds for such services are taxable only in that State, except when the individual is both resident and national of the other State. Articles 16, 17 and 19 apply to services connected with a State's business, and paragraph 1 extends to specified public financial institutions and mutually recognized organizations.
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