Government service remuneration taxable only in paying State, with residency and nationality exceptions allowing other State taxation. Salaries, wages and similar remuneration paid by a Contracting State or its subdivisions for services to that State are taxable only in that State, except where services are rendered in the other State and the individual is a resident who is a national or did not become resident solely to perform the services. Pensions paid by or out of funds of a Contracting State are similarly taxable only in that State, except where the recipient is both resident and national of the other State. Remuneration connected to a State-run business follows the rules applicable to employment and business income.
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 only in paying State, with residency and nationality exceptions allowing other State taxation.
Salaries, wages and similar remuneration paid by a Contracting State or its subdivisions for services to that State are taxable only in that State, except where services are rendered in the other State and the individual is a resident who is a national or did not become resident solely to perform the services. Pensions paid by or out of funds of a Contracting State are similarly taxable only in that State, except where the recipient is both resident and national of the other State. Remuneration connected to a State-run business follows the rules applicable to employment and business income.
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