Government remuneration exemptions for nationals performing official duties abroad prevent taxation by the host state under the treaty. Remuneration (other than pensions) paid by a Contracting State to its national for services performed in the other Contracting State in discharge of governmental functions is exempt from tax in that other State; pensions paid by a Contracting State in respect of services rendered to that Government are taxable only in the paying Contracting State; these provisions do not apply to remuneration or pensions for services rendered in connection with any trade or business.
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 exemptions for nationals performing official duties abroad prevent taxation by the host state under the treaty.
Remuneration (other than pensions) paid by a Contracting State to its national for services performed in the other Contracting State in discharge of governmental functions is exempt from tax in that other State; pensions paid by a Contracting State in respect of services rendered to that Government are taxable only in the paying Contracting State; these provisions do not apply to remuneration or pensions for services rendered in connection with any trade or business.
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