Governmental functions: remuneration and pensions from state funds generally taxable only in the paying state, with profit-making exceptions. Article 19 provides that remuneration paid by or out of funds created by a Contracting State, its political subdivisions or local authorities to a citizen in respect of employment is taxable only in that State, and that any pension so paid may be taxed in that Contracting State. Paragraph (1) does not apply to payments for services connected with any business carried on by a Contracting State or its subdivisions for profit. The term Government includes State Governments and local authorities and explicitly encompasses central banking institutions.
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.
Governmental functions: remuneration and pensions from state funds generally taxable only in the paying state, with profit-making exceptions.
Article 19 provides that remuneration paid by or out of funds created by a Contracting State, its political subdivisions or local authorities to a citizen in respect of employment is taxable only in that State, and that any pension so paid may be taxed in that Contracting State. Paragraph (1) does not apply to payments for services connected with any business carried on by a Contracting State or its subdivisions for profit. The term Government includes State Governments and local authorities and explicitly encompasses central banking institutions.
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