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ARTICLE 19
Government Functions
(1)
- (a) Remuneration including pensions paid by a Contracting State, a Land, a political sub-division or a local authority thereof to any individual in respect of services rendered to that State, Land, sub-division of local authority thereof 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 recipient is a resident of that State, so however, that
- (i) he is not a national of the Contracting State referred to in sub-paragraph (a); or
- (ii) he did not become a resident of the other Contracting State solely for the purpose of performing the services.
(2) The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with any trade or business carried on by a Contracting State, a Land, a political sub-division or a local authority thereof.
(3) 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 local authority thereof, out of funds exclusively supplied by that State, Land, political sub-division or local authority, to a specialist or volunteer seconded to the other Contracting state with the consent of that other State.