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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) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that Contracting State or subdivision or authority shall be taxable only in that Contracting State.

(2) However, such salaries, wages 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) is a national of that Contracting State; or
  • (ii) did not become a resident of that Contracting State solely for the purpose of rendering the services.

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

(4) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that Contracting State.

(5) The provisions of Articles 15, 16, 17 and 18 shall apply to remuneration or pensions in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof.

(6) The provisions of paragraphs 1 to 5 shall likewise apply in respect of salaries, wages, pensions, and other similar remuneration paid by a government owned institution performing functions of a governmental nature, which in the case of the United Arab Emirates shall include the Emirates Investment Authority, the Abu Dhabi Investment Authority, the Abu Dhabi Investment Council, the Mubadala Development Company, the Abu Dhabi Retirement Pensions and Benefits Fund, the General Pension and Social Security Authority and the Investment Corporation of Dubai and in case of the Slovak Republic shall include Eximbanka SR (Export-import Bank of the Slovak Republic), Slovenska zarucna a rozvojova banka, a.s. (Slovak Guarantee and Development Bank), Agentura pre riadenie dlhu a likvidity (Debt and Liquidity Management Agency) and Slovenska agentura pre rozvoj investicii a obchodu (Slovak Investment and Trade Development Agency).