ARTICLE 19

GOVERNMENT SERVICE

(1)

• (a) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof, or by another statutory body of that State, to an individual in respect of services rendered to that State, subdivision, authority or body shall be taxable only in that State.
• (b) However, such 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:
  • (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) Any pension paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereof, or by another statutory body of that State, to an individual in respect of services rendered to that State, subdivision, authority or body 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 remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof or by another statutory body of that State.

(4) The provisions of paragraph (1) shall likewise apply to remuneration paid, under a development assistance programme of a Contracting State or a political subdivision or a local authority thereof, out of funds exclusively supplied by that State, subdivision or authority, to a specialist or volunteer seconded to the other Contracting State with the consent of that other State.

(5) The provisions of paragraphs (1) and (2) shall also apply to remuneration paid to an individual for services rendered to the Goethe Institute or the German Academic Exchange Service of the Federal Republic of Germany. The competent authorities of the Contracting States may agree by mutual agreement to grant a similar treatment to remuneration paid by other comparable institutions of the Contracting States. If such remuneration is not taxed in the State in which the institution was founded, the provisions of Article 15 shall apply.