ARTICLE 19

Government Service

(1)

• (a) Salaries, wages and similar compensations, paid by a Contracting State or by its political or administrative subdivisions or local authorities to an individual in respect of services rendered to that Contracting State or one of its political or administrative sub-division or local authority, 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 other State and the individual is a resident of that State who:
  • (i) is a national of that Contracting State, or
  • (ii) did not become a resident of that State solely for the purpose of rendering services.

(2)

• (a) Any pension paid by, or out of funds created by a Contracting State or by its political or administrative sub-divisions or local authorities, to an individual in respect of services rendered to that State, subdivision or authority, shall be taxable only in that State.
• (b) However, such pensions shall be taxable only in the other Contracting State if the individual is a resident and a national of that other Contracting State.

(3) The provisions of Articles 15, 16, 17 and 18 of this Convention shall apply toremuneration and pensions in respect of services rendered in connection with business carried on by a Contracting State or its political or administrative sub-divisions or local authorities thereof.

(4) The provision of paragraph (1) shall also apply to compensation paid from the funds of a Contracting State or a political or administrative sub-division or local authority to a specialist or volunteer of the other Contracting State in respect of services rendered in connection with business carried on within the framework of an economic co-operation program between the Contracting States.

(5) The provisions of paragraphs (1) and (2) shall apply to salaries, wages and similar remuneration paid to an individual by the competent authorities of the Contracting States with respect to services rendered in the Goethe Institute (Goethe-Institut), in the German Academic Exchange Service (Deutsche AkademischeAustauschdienst - DAAD) and other similar services established within the framework of mutual agreements. Such payments made in a Contracting State shall not be taxed under the provisions of Article 15 of this Convention.