Government service remuneration taxable in paying state, except when services are rendered elsewhere by resident nationals or non solely resident individuals. Remuneration paid by a Contracting State, its political subdivisions, local authorities or statutory bodies is taxable only in the paying State, except where services are rendered in the other Contracting State and the recipient is a resident of that other State who is a national or did not become resident solely to perform the services; in that case taxation is in the State where services are rendered. Pensions paid by or from funds of a Contracting State or its entities are taxable only in the paying State. Articles 15, 16 and 18 apply to remuneration and pensions connected with any trade or business carried on by a State entity.
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 taxable in paying state, except when services are rendered elsewhere by resident nationals or non solely resident individuals.
Remuneration paid by a Contracting State, its political subdivisions, local authorities or statutory bodies is taxable only in the paying State, except where services are rendered in the other Contracting State and the recipient is a resident of that other State who is a national or did not become resident solely to perform the services; in that case taxation is in the State where services are rendered. Pensions paid by or from funds of a Contracting State or its entities are taxable only in the paying State. Articles 15, 16 and 18 apply to remuneration and pensions connected with any trade or business carried on by a State entity.
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