Government services: state-paid salaries and pensions taxable in paying state, with residence-based exceptions permitting taxation elsewhere. Salaries, wages and similar remuneration paid by a Contracting State or its subdivisions for services to that State are taxable only in the paying State, except where services are rendered in the other State and the individual is a resident who is either a national of that State or did not become resident solely to render the services. Pensions paid by the State or from State-created funds are taxable only in the paying State unless the recipient is both resident and a national of the other State. Articles on employment and related matters apply when services are connected to a State-run business.
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 services: state-paid salaries and pensions taxable in paying state, with residence-based exceptions permitting taxation elsewhere.
Salaries, wages and similar remuneration paid by a Contracting State or its subdivisions for services to that State are taxable only in the paying State, except where services are rendered in the other State and the individual is a resident who is either a national of that State or did not become resident solely to render the services. Pensions paid by the State or from State-created funds are taxable only in the paying State unless the recipient is both resident and a national of the other State. Articles on employment and related matters apply when services are connected to a State-run business.
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