Taxation of government remuneration: payments generally taxable only in the paying state, with residency and nationality exceptions. Remuneration (other than pensions) paid by a Contracting State or its subdivisions for services to that State is taxable only in the paying State, except where services are rendered in the other State and the individual is a resident there who is a national or did not become resident solely to render the services. Pensions paid by or from funds created by a Contracting State for services to that State are taxable only in the paying State, except where the individual is both resident and national of the other State. Business-related payments are governed by the treaty provisions 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 remuneration: payments generally taxable only in the paying state, with residency and nationality exceptions.
Remuneration (other than pensions) paid by a Contracting State or its subdivisions for services to that State is taxable only in the paying State, except where services are rendered in the other State and the individual is a resident there who is a national or did not become resident solely to render the services. Pensions paid by or from funds created by a Contracting State for services to that State are taxable only in the paying State, except where the individual is both resident and national of the other State. Business-related payments are governed by the treaty provisions on business income.
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