(1)

• (a) Salaries, wages and other similar remuneration, other than a pension, paid by an authority administering a territory or a subdivision thereof, or by a local authority of that territory or some other legal entity under public law of that territory as approved by the competent authority of that territory to an individual in respect of services rendered in charge of public or administrative functions on behalf of such an authority or such other legal entity under public law of that territory shall be taxable only in that territory.
• (b) However, such salaries, wages, and other similar remuneration shall be taxable only in the other territory if the services are rendered in that territory and if the individual is a resident of that territory and:
  • (i) is a national of that territory; or
  • (ii) did not become a resident of that territory solely for the purpose of rendering the services.

(2)

• (a) Any pension paid by, or out of funds created by, an authority administering a territory or some other above-mentioned legal entity under public law of that territory to an individual in respect of services rendered to that territory or that other legal entity under public law shall be taxable only in that territory.
• (b) However, such pension shall be taxable only in the other territory if the individual is a resident of, and a national of, that territory.

(3) The provisions of Articles 14, 15, 16 or 17 shall apply to salaries, wages and other similar remuneration, and to pensions in respect of services rendered in connection with a business carried on by a territory or some other above-mentioned legal entity under public law of that territory.