ARTICLE 18

Government Service

(1)

• (a) The wages, salaries and other similar remunerations, paid by a Contracting State, its Federal States, political subdivisions or local entities, or by any other body corporate pertaining to public law of that State, to an individual due to services rendered to that State, Federal State, subdivision, local entity or body corporate pertaining to public law, shall only be liable to taxation in that State.
• (b) However, such wages, salaries and similar remuneration may be liable to taxation exclusively in the other Contracting State, if the services are performed in that State and the individual is a resident of that State who:
  • (i) is a national of that State; or
  • (ii) did not become a resident of that State solely for the purpose of performing the services.

(2)

• (a) Notwithstanding the provisions of paragraph (1) of this Article, the pensions and other similar remunerations, paid directly by, or out of funds created by a Contracting State, its Federal States, political subdivisions or local entities, or by any other body corporate pertaining to public law of that State, to an individual due to services rendered to that State, Federal State, subdivision, local entity or body corporate pertaining to public law, shall only be liable to taxation in that State.
• (b) However, the aforementioned pensions and similar remunerations may only be liable to taxation in the other Contracting State, if the individual is a resident and national of that State.

(3) The provisions of Articles 14, 15, 16 and 17 of this Convention are applicable to wages, salaries, pensions and other similar remuneration paid in respect of services rendered within the framework of business activities performed by a Contracting State, its Federal States, political subdivisions or local entities, or by a body corporate pertaining to public law of such State.

(4) The provisions of paragraph (1) and (2) of this Article are likewise applicable to wages, salaries, pensions and any other similar remuneration, paid to individuals for services rendered to the Goethe Institute, to the German Academic Exchange Service (Deutscher Akademischer Austauschdienst), as well as to the Cervantes Institute. The competent authorities may mutually agree on granting similar treatment to remuneration paid by other comparable institutions of the Contracting States.