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Introducing the βIn Favour Ofβ filter in Case Laws.
Try it now in Case Laws β


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<h1>Article 19 of DTAA: Income from Government Functions Taxable Only in State of Payment, Excludes Profit-Driven Activities.</h1> Article 19 of the Double Tax Avoidance Agreement (DTAA) between two Contracting States addresses the taxation of income related to governmental functions. Remuneration paid by a Contracting State, its political subdivisions, or local authorities to its citizens for employment is taxable only in that State. Pensions paid by these entities to individuals may also be taxed in the paying State. However, this provision does not apply to payments for services related to profit-driven government business activities. The term 'Government' includes State Governments, local authorities, and specifically the Reserve Bank of India and the Bank of Zambia.