Government service: primary taxing rights lie with the payer State, with residency and nationality exceptions determining alternate taxation. Allocation of taxing rights for remuneration and pensions from Government service places primary taxation in the paying Contracting State, except where remuneration is for services rendered in the other State and the individual is resident there and either a national or not resident solely to perform the services; similarly, pensions are taxable only in the other State when the recipient is both resident and national there. Payments tied to any business carried on by a Contracting State or its subdivisions are governed by Articles 16, 17 and 19.
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: primary taxing rights lie with the payer State, with residency and nationality exceptions determining alternate taxation.
Allocation of taxing rights for remuneration and pensions from Government service places primary taxation in the paying Contracting State, except where remuneration is for services rendered in the other State and the individual is resident there and either a national or not resident solely to perform the services; similarly, pensions are taxable only in the other State when the recipient is both resident and national there. Payments tied to any business carried on by a Contracting State or its subdivisions are governed by Articles 16, 17 and 19.
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