background image
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

Remuneration of Government Employees

(1) Wages and other similar remuneration, other than pensions, paid by organs of State authority and administration created by a Contracting State to an individual for services rendered of a governmental character shall be taxable only in that State.

However, such wages and other similar remuneration may be taxable only in the other Contracting State, if the service is rendered in that other State and the individual who has permanent residency in that other State:

  • (a) is a citizen of that State; or
  • (b) did not become a person with permanent residency in that State solely for the purpose of rendering such service.

(2) The provisions of paragraph (1) of this article shall not apply to remuneration in respect to services rendered in connection with the exercise of business activity in a Contracting State by the above-mentioned organs. In that case the provisions of articles 15 and 16 of the present convention shall apply.