Government remuneration and pensions are taxable only in the paying Contracting State, subject to a commercial-activity exception. Remuneration (other than a pension) and pensions paid by a Government of a Contracting State to its citizens for services rendered are taxable only in the paying Contracting State; this exclusivity does not apply to payments for services connected with any profit-making business carried on by a Government. 'Government' includes state, canton, local or statutory authorities and specified central banking institutions.