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Untd A Emirates - Iraq Tax Treaty (2017, not yet in force) — Orbitax Tax Hub

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 20

Government Service

(1)

  • (a) Salaries, wages and other similar remunerations-otherwise pensions-paid for a person by a Contracting State, any of municipalities, local authority or legal department thereof, for services rendered to that State, local authority or legal department thereof, shall be taxable only in that State.
  • (b) Notwithstanding this, such remunerations are taxable only in the other Contracting State if the services are performed in that State and if the person is a resident of that State, holds a nationality of that State and has not become a resident of that country solely for the purpose of providing the Services.

(2)

  • (a) Any pension paid by or generated out of funds for a person by a Contracting State, any of municipalities, local authority or legal department thereof, for services rendered to that State, local authority or legal department thereof, shall be taxable only in that State.
  • (b) However, the pension shall be taxable in the other Contracting State if the person is a national and resident of that other Contracting State

(3) The provisions of Articles 15, 16, 18 and 19 apply to salaries, wages and similar remuneration or pension in respect of services rendered in the course of business carried on by a person of a Contracting State or its local authorities, or its local administrative subdivisions.

(4) The provisions of paragraph (1) of this Article shall also apply to salaries, wages and other similar remunerations and pensions paid by enterprises wholly owned by the Government.