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ARTICLE 19
Government Service
(1)
- (a) Remuneration other than a pension, paid by a Contracting State, a land, a political sub-division or a focal authority thereof to an individual in respect of services rendered to that State, land, sub-division or 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 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 a Contracting State, a Land, a political sub-division or a focal authority thereof to an individual in respect of services rendered to that State, land, sub-division or authority 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 other State.
(3) The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State, a Land, a political sub-division or a local authority thereof.
(4) The provisions of paragraph (1) shall likewise apply in respect of remuneration paid, under a development assistance programme of a Contracting State, a Land, a political sub-division or a focal authority thereof out of funds exclusively supplied by that State, Land, political sub-division or focal authority, to a specialist or volunteer seconded to the other Contracting State with the consent of that other State.