Government service remuneration and pensions are generally taxable only in the paying State, with limited residence-based exceptions. Article 19 provides that salaries, wages and similar remuneration (excluding pensions) paid by a Contracting State or its political subdivisions for services to that State are taxable only in that State, except when services are rendered in the other Contracting State by a resident who is a national or did not become resident solely to render the services; in that case taxation is only in the State of performance. Pensions paid by or from State-created funds for State services are taxable only in that State except where the recipient is both resident and national of the other State. Articles 15-18 apply where the services are connected with a State-run business.
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 and pensions are generally taxable only in the paying State, with limited residence-based exceptions.
Article 19 provides that salaries, wages and similar remuneration (excluding pensions) paid by a Contracting State or its political subdivisions for services to that State are taxable only in that State, except when services are rendered in the other Contracting State by a resident who is a national or did not become resident solely to render the services; in that case taxation is only in the State of performance. Pensions paid by or from State-created funds for State services are taxable only in that State except where the recipient is both resident and national of the other State. Articles 15-18 apply where the services are connected with a State-run business.
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