Government service taxation: state paid remuneration and pensions generally taxable only in the paying State, with limited residence exceptions. Remuneration for services to a Contracting State or its sub divisions is taxable only in the paying State, except where services are rendered in the other State and the individual is a resident who is a national or did not become resident solely to render services. Pensions paid by or from funds of a Contracting State are taxable only in the paying State, except when the recipient is both resident and national of the other State. Remuneration and pensions tied to a business carried on by a State are subject to the treaty provisions applicable to business activities.
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 taxation: state paid remuneration and pensions generally taxable only in the paying State, with limited residence exceptions.
Remuneration for services to a Contracting State or its sub divisions is taxable only in the paying State, except where services are rendered in the other State and the individual is a resident who is a national or did not become resident solely to render services. Pensions paid by or from funds of a Contracting State are taxable only in the paying State, except when the recipient is both resident and national of the other State. Remuneration and pensions tied to a business carried on by a State are subject to the treaty provisions applicable to business activities.
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