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)
- (a) Remuneration other than a pension paid by a Contracting State or a political or administrative subdivision or a local authority thereof to any individual in respect of services rendered to that State, or subdivision or authority shall be taxable only in that State.
- (b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State, and the individual is a resident of that State who :
- (i) is a national of that state, or
- (ii) did not become a resident of that State solely for the purpose of rendering the services.
(2)
- (a) Any pension paid by, or out of funds created by, a Contracting State or a political or administrative subdivision or a local authority thereof to any individual in respect of serviced rendered to that State or subdivision or authority shall be taxable only in that State.
- (b) However, such pension shall be taxable only in the other Contracting State if the individual is a national of and a resident of that State
(3) The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State, or a political or administrative subdivision or a local authority thereof.