ARTICLE 19

Government Service

(1)

• (a) Wages, salaries and similar compensations excluding retirement pensions that are paid by a Contracting State, one of its provinces, or one of their geographic sub-units to a natural person for services rendered to this State, one of its provinces or their geographic sub-units, can only be taxed in this State.
• (b) These compensations can however only be taxed in the other Contracting State if the services were rendered in this State and the natural person is resident in this State and
  • (aa) is a national of this States or
  • (bb) did not exclusively become a resident of this State to perform these services.

(2)

• (a) Retirement pensions that are paid by a Contracting State, one of its provinces or one of their geographic units or from special bodies of assets that were established be this State, one of its provinces or one of their geographic units to a natural person for services rendered to this State, one of its provinces, or one of their geographic sub-units, can only be taxed in this State.
• (b) These retirement pensions can however only be taxed in the other Contracting State if the natural person is resident in this State and is a citizen of this State.

(3) Article 15, 16, 17 or 18 is to be applied to compensations and retirement pensions for services that are rendered in connection with a commercial activity of a Contracting State, one of its provinces or its geographic sub-units.

(4) Paragraph (1) applies analogously to compensations that are paid in the framework of a programme of economic cooperation with a Contracting State, one of its provinces or one of its geographic sub-units from funds that are exclusively provided by this State, the province or the geographic sub-unit to specialists or volunteers who were sent to the other Contracting State with its consent.

(5) Paragraphs (1) and (2) apply analogously to compensations that are paid by, or for the Goethe Institute or German Academic Exchange Services of the Federal Republic of Germany. A corresponding treatment of the compensation of other comparable institutions of the Contracting States can be agreed on by the competent authorities of the Contracting States in mutual consultation. If these compensations are not taxed in the State where the institution was founded, Article 15 applies.