Government functions: exclusive taxing right for the paying State over remuneration and pensions for its citizens. Remuneration and pensions paid by a Contracting State to its citizens for governmental functions performed in the other State are taxable only in the paying State; payments for government activities carried on for profit are excluded. The term 'Government' includes local and statutory authorities and central banks and, for one Contracting State, state governments.
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 functions: exclusive taxing right for the paying State over remuneration and pensions for its citizens.
Remuneration and pensions paid by a Contracting State to its citizens for governmental functions performed in the other State are taxable only in the paying State; payments for government activities carried on for profit are excluded. The term "Government" includes local and statutory authorities and central banks and, for one Contracting State, state governments.
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