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Finland - Germany Tax Treaty (as amended by 2019 protocol) — Orbitax Tax Hub

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) Salaries, wages and other similar remuneration, paid by a Contracting State, one of its "Länder", or one of their political subdivisions or local authorities, or any other statutory body of that State, to an individual in respect of services rendered to that State, "Land", political subdivision, local authority or statutory body, shall be taxable only in that State. 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:

  • (a) is a national of that State; or
  • (b) did not become a resident of that State solely for the purpose of rendering such services.

(2) Notwithstanding the provisions of paragraph (1) of this Article, pensions and other similar remuneration paid by, or out of funds created by, a Contracting State, one of its "Länder", or one of their political subdivisions or local authorities, or any other statutory body of that State, to an individual in respect of services rendered to that State, "Land", political subdivision, local authority or statutory body, shall be taxable only in that State. However, such pensions and other similar remuneration 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 14, 15, 16 and 17 of this Convention shall apply to salaries, wages, pensions and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State, one of its "Länder", or one of their political subdivisions or local authorities, or any other statutory body of that State.

(4) The provisions of paragraphs (1) and (2) of this Article shall likewise apply in respect of salaries, wages, pensions and other similar remuneration paid to an individual in respect of services rendered to the Goethe Institute and the German Academic Exchange Service (DeutscherAkademischerAustauschdienst, DAAD). If such remuneration is not taxed in the State in which the institution was founded, the provisions of Article 14 of this Convention shall apply. Corresponding treatment of the remuneration of other comparable institutions of the Contracting States may be arranged by the competent authorities by mutual agreement.