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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 19

Government Service

(1) Wages, salaries, and other similar remunerations, other than pensions, paid by a Contracting State, a political subdivision, a local authority or a statutory body thereof, to an individual in respect of services rendered to that State, political subdivision, local authority or body, shall be taxable only in that State.

(2) However, such wages, salaries, and other similar remunerations may be taxed in the other Contracting State if the services are rendered in that other State and the individual is a resident of that State who:

  • (a) is a national of that State; or
  • (b) did not become a resident of that State solely for the purpose of rendering the services.