Article 19 - Government service

Government service taxation: State-paid remuneration and pensions generally taxable only in the paying State, with specified exceptions.

Remuneration paid by a Contracting State or its subdivisions for services rendered to that State is normally taxable only in the paying State, except when services are rendered in the other Contracting State and the individual is a resident who is a national or did not become resident solely to render the services, in which case taxability falls to that other State. Pensions paid by or from State funds for such services follow the same rule, but are taxable only in the other State if the pensioner is both resident and a national; Articles 16, 17 and 20 govern cases tied to State business.