Government service remuneration and pensions: sourcing rules generally assign taxation to the paying state with residency exceptions. Remuneration for government service is taxable only in the paying Contracting State, except when services are rendered in the other State and the individual is a resident who is a national or not resident solely for the services; pensions paid by a Contracting State or from its funds are taxable only in that State, except where the recipient is both resident and national of the other State. Remuneration and pensions tied to a State-run business follow Articles 16-18, with exclusive taxation in the other State if the person is supported substantially from that State's public funds.
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 service remuneration and pensions: sourcing rules generally assign taxation to the paying state with residency exceptions.
Remuneration for government service is taxable only in the paying Contracting State, except when services are rendered in the other State and the individual is a resident who is a national or not resident solely for the services; pensions paid by a Contracting State or from its funds are taxable only in that State, except where the recipient is both resident and national of the other State. Remuneration and pensions tied to a State-run business follow Articles 16-18, with exclusive taxation in the other State if the person is supported substantially from that State's public funds.
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