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ARTICLE 19
Government Service
(1)
- (a) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or one of its political subdivision or local authority to an individual in respect of services rendered to that State or political subdivision or local authority shall be taxable only in that State;
- (b) 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 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 the services.
(2)
- (a) Pension paid by a Contracting State or one of its political subdivision or local authority whether directly or by drawing upon funds created for that purpose to an individual in respect of services rendered in that State or political subdivision or local authority shall be taxable only in that State;
- (b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.
(3) The provisions of Articles 15, 16, 17, and 18 shall apply to salaries, wages and other similar remuneration, and to pensions, in respect of services rendered in connection with a business carried on by a Contracting State or one of its political subdivision or local authority.
(4) The provision of paragraph (1) of this Article shall apply to remuneration paid to experts or volunteers sent to a Contracting State with its approval in respect of programs of economic cooperation of the Contracting State, one of its administrative, or other political subdivisions, paid from public funds available solely for such purposes.