Taxation of governmental remuneration: state may tax salaries and pensions paid for discharge of governmental functions, including state entities. Remuneration, including pensions, paid by a Contracting State or its political subdivisions or local authorities for services rendered in discharge of governmental functions may be taxed by that State. The rule also applies to payments by specified public organisations and authorities; where those entities engage in trade or business activities, the treaty's provisions on employment and business remuneration (articles XVI, XVII and XIX) govern tax treatment.
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.
Taxation of governmental remuneration: state may tax salaries and pensions paid for discharge of governmental functions, including state entities.
Remuneration, including pensions, paid by a Contracting State or its political subdivisions or local authorities for services rendered in discharge of governmental functions may be taxed by that State. The rule also applies to payments by specified public organisations and authorities; where those entities engage in trade or business activities, the treaty's provisions on employment and business remuneration (articles XVI, XVII and XIX) govern tax treatment.
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