ARTICLE 18
Government Service
(1)
- (a) Salaries wages and similar remunerations that are paid by a Contracting State, one of its regional authorities or another legal person under public law of this State to an individual for services rendered for this State, the regional authority or other legal person under public law can only be taxed in this State.
- (b) These salaries, wages and similar remunerations can however only be taxed in the other Contracting State if the services were performed in this State and the individual is resident in this State and (a) is a citizen of this State or (b) did not take up residence in this State solely for the purpose of performing services.
(2)
- (a) Irrespective of the provisions of Paragraph (1) of this Article, pension payments that are paid by a Contracting State, one of its regional authorities or another legal person under the public law of this State or by a special fund established by one to an individual for services rendered to this State, regional authority or other legal person under the public law of this State, can only be taxed in this State.
- (b) These pension payments however can only be taxed in the other Contracting State if the individual is resident in this State and is a citizen of this State.
(3) Articles 14, 15, 16 or 17 are to be applied to salaries, wages and similar fees and pension payments for services that were rendered in connection with a business activity of a Contracting State, one of its regional authorities or another legal person under the public law of this State.
(4) This Article also shall apply to salaries, wages and similar fees (as well as to pension payments) that are paid to individuals who performed services for the Goethe-Institute, the Deutschen Akademischen Austauschdienst and other similar institutions to be identified by the responsible authorities in mutual agreement, on the conditions that these payments are subject to taxation in the Contracting State from which they originate.