Taxation of government remuneration and pensions: payments to State nationals are taxable only in the paying State, with profit making exceptions.

Remuneration and pensions paid by a Contracting State to its nationals for services rendered to that State are taxable only in the paying State, except where such payments relate to services connected to any business carried on by the Government for profit. Remuneration under a development assistance programme to secondees is similarly covered. For these purposes, "Government" includes State, local or statutory authorities and specified public financial institutions.

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