background image
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 Services

(1)

  • (a) Salaries, wages and other similar remuneration other than pensions, paid by a Contracting State or one of its political sub-divisions or local authorities to an individual, in respect of services rendered to that State or that political sub-division or local authorities, shall be taxed only in that State.
  • (b) Notwithstanding the provisions of sub-paragraph (a) of this Article, however, such remuneration shall be taxable only in the other Contracting State, and if the services are rendered in that State and if the individual who is a resident of that State:
    • (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)

  • (a) Any pensions paid by a Contracting State or one of its sub-divisions or local authorities to an individual, whether directly or by drawing upon funds created for that purpose, to an individual, in respect of services rendered in that subdivision or authorities, shall be taxable only in that State.
  • (b)   Notwithstanding the provisions of sub-paragraph (a) of this Article, however, such pensions shall be taxable only in the other Contracting State if an individual is a resident and a national of that State.

(3) The provisions of Articles 15, 18 and 19 of this Convention shall apply to remuneration and pensions paid in respect of services rendered in connection with an industrial or commercial activities carried on by a Contracting State or one of its political sub-divisions or local authorities.

(4) The provisions of this Article shall also apply to remuneration paid by a Contracting State to skilled or voluntary worker who are sent to the other Contracting State, in respect of assistance in development, signed by the Contracting States, where such activities are paid either directly or are exclusively funded by that Contracting State or one of its political sub- division or local authorities.