background image
Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 18

Government Service

(1)

  • (a) Salaries, wages and other similar remuneration, other than pensions, paid by a Contracting State or a local authority or a statutory body governed by public law to an individual in respect of services rendered in that State, authority or body shall be taxable only in that State.
  • (b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident and a national of that State, without being, at the same time, a national of the first-mentioned State.

(2)

  • (a) Any pension paid by a Contracting State or a local authority or a statutory body governed by public law, either directly or by means of funds created for the purpose, to an individual in respect of services rendered to that State, authority or body shall be taxable only in that State.
  • (b) However, such pensions shall be taxable only in the other Contracting State if the individual is a resident and a national of that State, without being, at the same time, a national of the first-mentioned State.

(3) The provisions of Articles 14, 15, 16 and 17 shall apply to salaries, wages and other similar remuneration, and to pensions paid in respect of services rendered in connection with an industrial or business activity carried on by a Contracting State or a local authority or a statutory body governed by public law.