Government service remuneration and pensions: source taxation subject to residency and nationality exceptions under the treaty. Remuneration (other than pensions) paid by a State or its sub division for services rendered to that employer may be taxed by the paying State, except that if the services are rendered in the other State and the individual is a resident who is either a national of that State or did not become resident solely to render the services, taxation is confined to the other State. Pensions paid by or from State funds may be taxed by the paying State, but are taxable only in the other State if the individual is both resident and a national there. Articles on employment income, directors' fees and independent services apply where services are connected with a State 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: source taxation subject to residency and nationality exceptions under the treaty.
Remuneration (other than pensions) paid by a State or its sub division for services rendered to that employer may be taxed by the paying State, except that if the services are rendered in the other State and the individual is a resident who is either a national of that State or did not become resident solely to render the services, taxation is confined to the other State. Pensions paid by or from State funds may be taxed by the paying State, but are taxable only in the other State if the individual is both resident and a national there. Articles on employment income, directors' fees and independent services apply where services are connected with a State business.
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