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ARTICLE 19
Government Service
(1)
- (a) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or one of its political subdivisions or local authorities thereof to an individual in respect of services rendered to that State or subdivision or authority 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 if the individual is a resident of that State who:
- (i) is a national of that State;
- (ii) has not become a resident of that State solely for the purpose of rendering the services.
(2) The provisions of Articles 15 and 16 of this Convention shall apply to salaries, wages and other similar remuneration in respect of services rendered in connection with an industrial or business activity carried on by a Contracting State or one of its political subdivisions or local authorities.