Government remuneration exemption protects pay for governmental functions from foreign taxation subject to residence and nationality conditions. Remuneration paid by a Contracting State for services in discharge of governmental functions is exempt from tax in the other State if the individual is not resident there or is resident there solely to render those services and is a national of the paying State; payments for services connected with any trade or business carried on by the Government for profit are excluded, and 'Government' includes public corporations and similar parastatal bodies.
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 exemption protects pay for governmental functions from foreign taxation subject to residence and nationality conditions.
Remuneration paid by a Contracting State for services in discharge of governmental functions is exempt from tax in the other State if the individual is not resident there or is resident there solely to render those services and is a national of the paying State; payments for services connected with any trade or business carried on by the Government for profit are excluded, and "Government" includes public corporations and similar parastatal bodies.
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