ARTICLE 19
Government Service
(1)
- (a) Salaries, wages and other similar remuneration, other than pensions, paid by a Contracting State or one of its political subdivision or local authority to an individual in respect of services rendered to that State, political subdivision or local authority shall be taxable only in that State;
- (b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and if the individual who is a resident of that State:
- (i) is a national of that State; or
- (ii) did not become a resident of that State solely for the purpose of rendering such services.
(2)
- (a) Any pension paid by a Contracting State or by one of its political or local authorities to an individual, either directly or out of funds created for that purpose, in respect of services rendered to that Contracting State, political or local authority, shall be taxable only in that State.
- (b) However, such pension shall also be taxed in the other Contracting State, if the individual is a resident and a national of that State.
(3) The provisions of Articles 15, 16 and 18 shall apply to salaries, wages and other similar remuneration, and to pensions, paid in respect of services rendered in connection with a business carried on by a Contracting State or by a political subdivision or a local authority.
(4) The provision of paragraphs (1) and (2) of this Article shall also apply to salaries, wages, pension payments, and other similar remuneration that are paid to an individual for services rendered to the Goethe Institute International, German Academic Exchange Service (DAAD), Polish Cultural Institute, or other similar institutions to be specified by the competent authorities of the Contracting States, provided that these payments are taxable in the State in which they originate.