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ARTICLE 19
Government Service
(1)
- (a) Salaries, wages and other similar remuneration, other than a pension, a Contracting State or a political subdivision or local authority of a Contracting State paid to an individual for services rendered to that State or subdivision or authority, only be taxed 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;
- (ii) did not become a resident of that State solely for the purpose of rendering the services.
(2)
- (a) Any pension paid to a person by, or out of funds created by a Contracting State or a political subdivision or a local authority with respect to services rendered to that State or subdivision or authority shall be subject only to taxed in that State.
- (b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident and national of that other State.
(3) The provisions of Articles 15, 16, 17 and 18 shall apply to salaries, wages and pensions in respect of services rendered in connection with a trade or business carried on by a Contracting State or a political subdivision or local authority thereof State.