Government services remuneration taxable only in the paying state, with resident and national exceptions when services performed abroad. Remuneration for public employment paid by a Contracting State or its subdivisions is generally taxable only in the paying State, except when services are performed in the other Contracting State and the individual is resident there and either a national or not resident solely to render the services. Pensions paid by or from funds of a Contracting State for such services are similarly taxable only in the paying State, unless the recipient is both resident and a national of the other State. Income tied to a State's business activities is governed by the treaty articles on business and service income.
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 services remuneration taxable only in the paying state, with resident and national exceptions when services performed abroad.
Remuneration for public employment paid by a Contracting State or its subdivisions is generally taxable only in the paying State, except when services are performed in the other Contracting State and the individual is resident there and either a national or not resident solely to render the services. Pensions paid by or from funds of a Contracting State for such services are similarly taxable only in the paying State, unless the recipient is both resident and a national of the other State. Income tied to a State's business activities is governed by the treaty articles on business and service income.
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