Government service taxation: remuneration and pensions generally taxable in the paying state, with resident-national exceptions. Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are generally taxable only in that State, but are taxable only in the other Contracting State if the services are rendered there and the individual is a resident who is a national or who did not become resident solely to render the services. Pensions paid by or from funds of a Contracting State for such services are likewise taxable only in that State, except when the recipient is both a resident and national of the other State. Remuneration and pensions connected with a State's business are governed by Articles 15-18.
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: remuneration and pensions generally taxable in the paying state, with resident-national exceptions.
Salaries, wages and similar remuneration paid by a Contracting State or its political subdivisions for services rendered to that State are generally taxable only in that State, but are taxable only in the other Contracting State if the services are rendered there and the individual is a resident who is a national or who did not become resident solely to render the services. Pensions paid by or from funds of a Contracting State for such services are likewise taxable only in that State, except when the recipient is both a resident and national of the other State. Remuneration and pensions connected with a State's business are governed by Articles 15-18.
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