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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 17

Government Service

(1)

  • (a) Remuneration other than pensions paid by a Contracting State, or a political subdivision or a local authority thereof to an individual in respect of services rendered to the Government of that State, or a political subdivision or a local authority shall be taxable only in that State.
  • (b) Such remuneration shall however be taxable only in the other Contracting State if the services in respect of which the remuneration is paid are rendered in the other Contracting State and the recipient is a resident and a national of that other State, provided that he did not become a resident of that other State solely for purpose of rendering the services.

(2) The provisions of Articles 14 and 15 shall apply to remuneration in respect of an employment in connection with any business carried on by a Contracting State, or political subdivision or a local authority thereof for the purpose of profits.