Government service taxation: paying State generally taxes remuneration and pensions, with residence and nationality exceptions.

Remuneration paid by a Contracting State or its political subdivisions or local authorities for services to that State is taxable only in the paying State, except when services are rendered in the other Contracting State and the individual is a resident who is a national of that State or did not become resident solely to perform the services. Pensions paid by or from funds of a Contracting State for such services are taxable only in the paying State, except when the recipient is both resident and national of the other State. Articles on dependent personal services, directors' fees, entertainers and athletes, and private pensions/annuities/alimony apply when services relate to a business carried on by the State.

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