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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 19

Government Service

(1)

  • (a) Remuneration, other than a pension, paid by the Government of a Contracting State, its local authority or local governments, to an individual in respect of services rendered to that State or its local authority or local government shall be taxable only in that State.
  • (b) However, such remuneration shall be taxable only in the other Contracting State, its local authority or local governments, if the services are rendered in that other 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 such services.

(2) Any pension paid by, or out of funds created by, a Contracting State, its local authority or local government thereof to an individual in respect of services rendered to that State, its local authority or local government shall be taxable only in 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, its local authority or local governments thereof.

(4) For the purpose of this Article, the term "Government" shall include any State Government or local authority of either Contracting State, and the Central Bank of either Contracting State.