ARTICLE 19

Government Service

(1) Remunerations, other than pensions, paid by a Contracting State, a Land, a political subdivision or a local authority thereof or some other legal entity under public law of that State to an individual in respect of services rendered to that State, a Land, a political subdivision or a local authority thereof or some other legal entity under public law shall be taxable only in that State. However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and if the individual is a resident of that State and:

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

(2) Notwithstanding the provisions of Article 18, pensions paid by a Contracting State, a Land, a political subdivision or a local authority thereof or some other legal entity under public law of that State to an individual in respect of services rendered to that State, a Land, a political subdivision or a local authority thereof or some other legal entity under public law shall be taxable only in the other Contracting State if the individual is a resident of that State and a national of that 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 subdivision or a local authority thereof or some other legal entity under public law of that State.

(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 subdivision or a local authority thereof, out of funds exclusively supplied by that State, Land, political subdivision or local authority, to a specialist or volunteer seconded to the other Contracting State with the consent of that other State.

(5) The provisions of paragraph (1) shall likewise apply in respect of remuneration paid by or for the Goethe Institute of the Federal Republic of Germany. Corresponding treatment of the remuneration of other comparable institutions of the Contracting States may be arranged by the competent authorities by mutual agreement. If such remuneration is not taxed in the State where the institution was founded, the provisions of Article 15 shall apply.