Government service remuneration taxable in paying state; exception where services are rendered abroad by resident nationals or non transient residents. Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions/local authorities for services to that public employer are taxable only in the paying State, except where 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 services, in which case taxation occurs only in the state of performance. Pensions paid by or from funds of the paying State are similarly taxable only in that State, unless the recipient is both resident and national of the other Contracting State. Remuneration and pensions connected with a business carried on by the State are subject to the general business connected employment rules.
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Provisions expressly mentioned in the judgment/order text.
Government service remuneration taxable in paying state; exception where services are rendered abroad by resident nationals or non transient residents.
Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions/local authorities for services to that public employer are taxable only in the paying State, except where 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 services, in which case taxation occurs only in the state of performance. Pensions paid by or from funds of the paying State are similarly taxable only in that State, unless the recipient is both resident and national of the other Contracting State. Remuneration and pensions connected with a business carried on by the State are subject to the general business connected employment rules.
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