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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.

ARTICLE 19

GOVERNMENT SERVICE

(1) Salaries, wages and other similar remuneration, paid by a Contracting State or a local authority thereof to an individual in respect of services rendered to that State or local authority shall be taxable only in that Contracting State.

However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State by an individual who is a resident of that State provided that he:

  • (i) is a national of that other Contracting State, or
  • (ii) did not become a resident of that State solely for the purpose of rendering the services.

(2) Any pension paid by, or out of funds created by, a Contracting State or a local authority thereof to an individual in respect of services rendered to that State or local authority shall be taxable only in that Contracting State.

(3) The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or a local authority thereof.