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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Government Functions/Civil Service

(1) Remuneration paid by the Government of one of the Contracting States to any individual for services rendered to that Government in the discharge of governmental functions shall be exempt from tax in other State if the individual is not resident in that other State or is resident in other State solely for the purpose of rendering those services, so provided however, that such an individual has the nationality of that Contracting State.

(2) The provision of this Article shall not apply to payments in respect of services rendered in connection with any trade or business carried on by either of the Government for purposes of profit.

(3) In this Article, "Government" shall be deemed to include public corporation and any other similar parastatal bodies.