Government service remuneration and pensions: taxation primarily in source state, with residency and nationality exceptions. Remuneration paid by a Contracting State or its subdivisions for services rendered to that State is taxable only in that State, except where services are performed in the other Contracting State and the individual is a resident of that other State who is a national of that State or did not become resident solely to render the services. Pensions paid by or from funds created by a Contracting State for such services are taxable only in that State, except where the recipient is both resident and national of the other Contracting State. Business-related remuneration and pensions follow the treaty provisions applicable to business profits.
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: taxation primarily in source state, with residency and nationality exceptions.
Remuneration paid by a Contracting State or its subdivisions for services rendered to that State is taxable only in that State, except where services are performed in the other Contracting State and the individual is a resident of that other State who is a national of that State or did not become resident solely to render the services. Pensions paid by or from funds created by a Contracting State for such services are taxable only in that State, except where the recipient is both resident and national of the other Contracting State. Business-related remuneration and pensions follow the treaty provisions applicable to business profits.
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