Government service remuneration and pension tax rules limit taxation to the paying State, with resident national exceptions. Remuneration for services to a Contracting State or its subdivisions is 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 perform the services. Similarly, pensions paid by or from funds of a Contracting State are taxable only in the paying State, except where the recipient is both a resident and national of the other Contracting State. Remuneration and pensions linked to a business carried on by a Contracting State are subject to the treaty rules governing business-connected services.
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 pension tax rules limit taxation to the paying State, with resident national exceptions.
Remuneration for services to a Contracting State or its subdivisions is 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 perform the services. Similarly, pensions paid by or from funds of a Contracting State are taxable only in the paying State, except where the recipient is both a resident and national of the other Contracting State. Remuneration and pensions linked to a business carried on by a Contracting State are subject to the treaty rules governing business-connected services.
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