Taxation of government service income: the sovereign employer generally retains taxing rights, with residency-based exceptions. Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are taxable only in the paying State, subject to a residency-based exception allowing the other State to tax if the services are performed there and the individual is a resident who is a national or did not become resident solely to render the services. Pensions paid by or from State-created funds are likewise taxable only in the paying State, except where the recipient is both resident and national of the other State. Remuneration for services connected with a State-carried business is governed by 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.
Taxation of government service income: the sovereign employer generally retains taxing rights, with residency-based exceptions.
Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are taxable only in the paying State, subject to a residency-based exception allowing the other State to tax if the services are performed there and the individual is a resident who is a national or did not become resident solely to render the services. Pensions paid by or from State-created funds are likewise taxable only in the paying State, except where the recipient is both resident and national of the other State. Remuneration for services connected with a State-carried business is governed by the rules applicable to employment and business income.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.