Remuneration and pensions taxed primarily in the paying State, with residency and nationality exceptions determining alternate taxation.

Remuneration and pensions paid by a Contracting State, its political sub division or local authority for services to that State are generally taxable only in the paying State, with exceptions: remuneration for services rendered in the other Contracting State is taxable there if the individual is resident and either a national or not resident solely to render services; pensions are taxable only in the paying State except where the pensioner is resident and a national of the other State. Payments tied to services connected with a State's business are governed by Articles 14-16.

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