Government service remuneration and pensions: allocation of taxing rights based on source and residence exceptions. Remuneration paid by a Contracting State or its subdivisions for services to that State is generally taxable only in that State, except when services are performed in the other Contracting State and the individual is a resident there who is either a national or did not become resident solely to render the services, in which case taxation is only in the State of residence; pensions paid by or from funds of a Contracting State are similarly taxable only in that State, except where the recipient is both resident and national of the other State. Articles governing personal services apply where payments arise from a business carried on by the State.
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Government service remuneration and pensions: allocation of taxing rights based on source and residence exceptions.
Remuneration paid by a Contracting State or its subdivisions for services to that State is generally taxable only in that State, except when services are performed in the other Contracting State and the individual is a resident there who is either a national or did not become resident solely to render the services, in which case taxation is only in the State of residence; pensions paid by or from funds of a Contracting State are similarly taxable only in that State, except where the recipient is both resident and national of the other State. Articles governing personal services apply where payments arise from a business carried on by the State.
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