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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 Services

(1)

  • (a) Salaries, wages and other similar remunerations - otherwise pensions - paid for a person by a Contracting State, any of municipalities or local authority thereof for services rendered to that State, department or authority shall be taxable only in that State.
  • (b) However, such salaries, wages and other similar remunerations shall be taxable only in the other Contracting State if the services are rendered in that State and the person is resident in that State as well as:
    • (i) any person holds the nationality of that State
    • (ii) or not resident in that State only for the purpose of rendering services.

(2)

  • (a) Any pension paid for a person by a Contracting State, municipalities or local authority thereof or out of funds provided by such, for services rendered to that State, department or authority shall be taxable only in that State.
  • (b) However, such pension is subject to tax in the other Contracting State only if the person is a citizen and a resident in that State.

(3) The provisions of Article 15, 16, 17 and 18 herein, shall apply to salaries, wages, other similar remunerations and pensions with respect to services rendered and in connection with business carried out by a Contracting State, any municipalities or local authority thereof.