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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

Remuneration and Pensions

(1) Remuneration other than pensions paid by a Contracting State or a Land or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or a Land or a subdivision or local authority thereof shall be taxable only in that State. However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State and the recipient of the remuneration is a resident of that State who is not a national of the first-mentioned State.

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

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

(4) Notwithstanding the provisions of paragraphs (1) and (3), remuneration paid by the Federal Republic of Germany to technical co-operation personnel under the Convention between the Government of the Federal Republic of Germany and the Government of the Republic of the Ivory Coast concerning technical co-operation of 21 August 1975 shall be taxable only in the Federal Republic of Germany.