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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 18

Government Service

(1) Salaries, wages and other similar remuneration, other than a pension paid by a Contracting State, a political subdivision or a local Government or a local authority thereof or some other legal entity under public law of that State to an individual in respect of services rendered to that State, subdivision or local Government or authority or other legal entity under public law of that State shall be taxable only in that State.

(2) Notwithstanding the provisions of paragraph 1, pensions and other similar remuneration (including lump-sum payments) paid by, or out of funds created by, a Contracting State or a political subdivision or a local Government or a local authority thereof or some other legal entity under public law of that State to an individual in respect of services rendered to that State, subdivision or local Government or authority or other legal entity under public law of that State shall be taxable only in that State.

(3) The provisions of Articles 14, 15, 16, and 17 shall apply to salaries, wages, pensions, and other similar remuneration (including lump-sum payments) in respect of services rendered in connection with a business carried on by a Contracting State, a political subdivision or a local Government or a local authority thereof or some other legal entity under public law of that State.