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ARTICLE 19

Civil Service

(1)

  • (a) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or local authority thereof to an individual in respect of services rendered to that State or subdivision or community, shall be taxable only in that State.
  • (b) However, such wages, salaries and other similar 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) proceeds to the nationality of that State; or
    • (ii) did not become a resident of that State solely for the purpose of rendering the services.

(2)

  • (a) pensions paid by a Contracting State or a political subdivision or local authority thereof, either directly or through funds derived by them from a natural person for services rendered to that State, to that subdivision or collectivity, shall be taxable only in that State.
  • (b) however, such pensions shall be taxable only in the other Contracting State if the natural person is a resident of that other State and is a national of that State.

(3) The provisions of Articles 15, 16, 17 and 18 shall apply to wages, salaries and other similar remuneration and to pensions paid in respect of services rendered in connection with a business carried on by a Contracting State or one of its political subdivisions and local authorities.