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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 18

Government Service

(1)

  • (a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to any individual in respect of services rendered to that State or subdivision or local authority thereof shall be taxable only in that State.
  • (b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the recipient is a resident of that other Contracting State who:
    • (i) is a national of that State; or
    • (ii) did not become a resident of that State solely for the purpose of performing the services; or
    • (iii) is not subject to tax in respect of such remuneration in the Contracting State from which the remuneration is paid.

(2)

  • (a) Any pension paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereof to any individual in respect of services rendered to that State or subdivision or local authority thereof shall be taxable only in that State.
  • (b) However, such pension shall be taxable only in the other Contracting State if the recipient is a national of and a resident of that State.

(3) The provisions of Articles 15, 16 and 19 shall apply to remuneration and pension in respect of services rendered in connection with any business carried on by a Contracting State or a political subdivision or a local authority thereof.