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ARTICLE 19
Government Service
(1)
- (a) Salaries, wages and other remuneration paid by a Contracting State or a political subdivision or local government thereof to an individual in respect of services rendered to that Contracting State or political subdivision or local government shall be taxable only in that Contracting State.
- (b) However, such salaries, wages and other remuneration shall be taxable only in the other Contracting State if the services are rendered in that other Contracting State and the individual is a resident of that other Contracting State who:
- (i) is a national of that other Contracting State; or
- (ii) did not become a resident of that other Contracting State solely for the purpose of rendering the services.
(2) The provisions of Articles 15, 16 and 17 shall apply to salaries, wages and other remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or local government thereof.