Taxation of government remuneration: paying state taxed unless resident national performs services in the other state. Remuneration (other than pensions) paid by a Contracting State, its political subdivisions or local authorities for services rendered to that State is taxable only in the paying State, except when services are rendered in the other Contracting State and the individual is a resident there who is either a national or not resident solely to render the services, in which case taxation is confined to the other State. Pensions paid by or from funds of a Contracting State are taxable only in the paying State unless the recipient is both resident and national of the other State. Articles 15, 16 and 19 apply where services relate to a business carried on by the State or its subdivisions.
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: paying state taxed unless resident national performs services in the other state.
Remuneration (other than pensions) paid by a Contracting State, its political subdivisions or local authorities for services rendered to that State is taxable only in the paying State, except when services are rendered in the other Contracting State and the individual is a resident there who is either a national or not resident solely to render the services, in which case taxation is confined to the other State. Pensions paid by or from funds of a Contracting State are taxable only in the paying State unless the recipient is both resident and national of the other State. Articles 15, 16 and 19 apply where services relate to a business carried on by the State or its subdivisions.
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