Taxation of government service remuneration: normally taxable in the paying State, with residency and service exceptions. Remuneration paid by a Contracting State or its political subdivisions for governmental services is generally taxable only in the paying State, except when services are performed in the other Contracting State and the individual is a resident there who is a national or did not become a resident solely to render services. Pensions from State funds for such services are also taxable only in the paying State, except where the recipient is both resident and national of the other State or the pension is exempt in the paying State. Remuneration and pensions connected with State run business activities are governed by the treaty rules on business income.
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.
Taxation of government service remuneration: normally taxable in the paying State, with residency and service exceptions.
Remuneration paid by a Contracting State or its political subdivisions for governmental services is generally taxable only in the paying State, except when services are performed in the other Contracting State and the individual is a resident there who is a national or did not become a resident solely to render services. Pensions from State funds for such services are also taxable only in the paying State, except where the recipient is both resident and national of the other State or the pension is exempt in the paying State. Remuneration and pensions connected with State run business activities are governed by the treaty rules on business income.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.