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ARTICLE 18
Government Service
(1)
- (a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision, a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that State.
- (b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State and the individual is a resident of that other State who:
- (i) is a national of that other State; or
- (ii) did not become a resident of that other State solely for the purpose of rendering the services.
(2)
- (a) Any pension paid by or out of funds created by a Contracting State or a political subdivision, a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable in that State.
- (b) However, such pension shall be taxable only in the Contracting State of which the individual is a resident if he is a national of that State.
(3) The provisions of Articles 14, 15 and 17 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision, a local authority or a statutory body thereof.