Government service remuneration taxable in the paying state, with residency and nationality exceptions under the treaty. Remuneration (other than pension) paid by a Contracting State or its subdivisions for services to that State 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 either a national or did not become resident solely to render the services, in which case taxation is in the State of residence. Pensions paid by or from funds of a Contracting State for such services are taxable only in the paying State, except when the recipient is both resident and national of the other State. Articles 15, 16 and 18 apply to business-related 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 taxable in the paying state, with residency and nationality exceptions under the treaty.
Remuneration (other than pension) paid by a Contracting State or its subdivisions for services to that State 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 either a national or did not become resident solely to render the services, in which case taxation is in the State of residence. Pensions paid by or from funds of a Contracting State for such services are taxable only in the paying State, except when the recipient is both resident and national of the other State. Articles 15, 16 and 18 apply to business-related services.
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