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ARTICLE 19
Government Service
(1)
- (a) Salaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a political and administrative subdivision or a local authority thereof to any individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.
- (b) However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State, who:
- (i) is a national of that State, or
- (ii) did not become a resident of that State solely for the purpose of rendering the services.
(2)
- (a) Any pension paid by, or out of funds created by, a Contracting State or a political and administrative subdivision or a local authority thereof to any individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.
- (b) However, such pension shall be taxable only in the other Contracting State if the individual is a national of and a resident of that State.
(3) The provisions of Articles 15, 16 and 18 shall apply to salaries, wages and other similar remuneration or pensions in respect of services rendered in connection with business carried on by one of the Contracting State or a political and administrative subdivision or a local authority thereof.