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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 18

Government Service

(1) Subject to the provisions of Article 19, remuneration paid by a Contracting State, a federated state thereof, or a political division or subdivision or a local authority thereof, directly or out of special funds created by the Contracting State, a federated state thereof, or a political division or subdivision or a local authority thereof, to an individual in respect of dependent activities, shall be taxable only in that State. If the dependent activity is performed in the other Contracting State by a national of the second-mentioned State, who is not a national of the first-mentioned State, the remuneration shall be taxable only in the second-mentioned State.

(2) Paragraph (1) shall apply correspondingly to remuneration paid in connection with a development assistance program of a Contracting State or of a federated state thereof, a political division or subdivision or local authority thereof, to experts or volunteers sent to the other Contracting State with the consent thereof, provided that such remuneration is paid out of public funds all of which have been contributed by that Contracting State, federated state, political division or subdivision or authority thereof.

Articles 15, 16 and 17 shall apply to remuneration in respect of an activity carried on for profit by a Contracting State, a federated state thereof, a political division or subdivision thereof, or a local authority thereof.