Government remuneration taxation: payments for governmental service taxed only in the paying state, with business exceptions. Remuneration (other than pensions) paid by a Government to its citizen for governmental services rendered in the other Contracting State is taxable only in the paying State; pensions paid by a Government may be taxed in the paying State. These rules exclude remuneration and pensions for services connected with any business carried on by the Government for profit. 'Government' includes State, local or statutory authorities and specified central banking institutions.
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 remuneration taxation: payments for governmental service taxed only in the paying state, with business exceptions.
Remuneration (other than pensions) paid by a Government to its citizen for governmental services rendered in the other Contracting State is taxable only in the paying State; pensions paid by a Government may be taxed in the paying State. These rules exclude remuneration and pensions for services connected with any business carried on by the Government for profit. "Government" includes State, local or statutory authorities and specified central banking institutions.
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