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ARTICLE 18

Government Service

(1)

  • (a) Salaries, wages and similar remunerations with the exception of pensions that are paid out by a Contracting State, its states/provinces or by one of political subdivisions to an individual for services rendered to this State or its states/provinces, political subdivisions or a public-law entity shall be taxed only in this State.
  • (b) These remunerations may however be taxed in the other Contracting State if the services are rendered in this State and the individual is a resident in this State, and:
    • (i) is a national of this State; or
    • (ii) has not exclusively become resident of this State in order to render such services.

(2)

  • (a) Pensions paid by one Contracting State, its states/provinces, its political divisions or any public-law entity or from out of a special fund created by the State, states/provinces, its political divisions or any public-law entity to an individual for services rendered to this State, states/provinces, one of its political divisions or any public-law entity, may be taxed in this State only.
  • (b) The pension may however be taxed only in the other Contracting State if the individual is a resident and national of this State.

(3) Articles 14, 15, 16 or 17 apply for salaries, wages and similar remunerations and pensions for services rendered, that are related to an industrial or commercial activity carried on by a Contracting State, its states/provinces, one of its political divisions or any of its public-law entity.

(4) Paragraph (1) applies accordingly to remuneration paid within the scope of an economic cooperation program of a Contracting State, one of its states/provinces, or on of its political subdivisions out of funds exclusively made available by this State, one of its states/provinces or one of its political subdivisions to skilled staff members or volunteers which were assigned to the other Contracting State with the consent of the first-mentioned State.

(5) Paragraphs (1) and (2) apply correspondingly to compensations that are paid by or for the Goethe Institute Inter Nationes, German Academic Exchange Service of the Federal Republic of Germany. A similar treatment for compensations to other comparable institutions of the Contracting States can be agreed upon by the competent authorities of the Contracting States in mutual understanding. If these compensations are not taxed in the Contracting States of these institutes, Article 14 shall apply.