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ARTICLE 18

Government Service

(1)

  • (a) Salaries, wages and such similar remuneration, other than pensions, paid by a Contracting State or by one of its political subdivisions or local authorities to an individual in respect of services rendered to that State, political subdivision or local authority, shall be taxable only in that Contracting 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 who is a resident of that State:
    • (i) is a national of that State; or
    • (ii) did not become a resident of that State solely for the purpose of rendering such services.

(2)

  • (a) Any pension paid, directly or out of funds created for that purpose, by a Contracting State or by one of its political subdivisions or local authorities to an individual in respect of services rendered to that Contracting State, political subdivision or local authority, shall be taxable only in that State.
  • (b) However, such pensions shall be taxable only in the other Contracting State if the recipient is a resident of that other State.

(3) The provisions of Articles 14, 15, 16 and 17 shall apply to salaries, wages and other similar remuneration, as well as to pensions, paid in consideration of services rendered in connection with a business carried on by a Contracting State or by one of its political subdivisions or local authorities.