Government service taxation: primary taxing right to the paying State, with resident-national exceptions for salaries and pensions.

Government service taxation grants the paying Contracting State exclusive taxation of salaries, wages and similar remuneration and of pensions paid by or from funds of that State, except that remuneration is taxable only in the other State if services are rendered there and the individual is a resident who is a national or not resident solely to render services, and pensions are taxable only in the other State if the individual is both resident and national of that other State. Articles 15-18 apply where services relate to a business carried on by the State.

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