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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 20

Government Service

(1)

  • (a) Salaries, wages and other similar remuneration, paid by a Contracting State or a local authority thereof to an individual in respect of services rendered to that State or authority in the discharge of functions of a governmental nature shall be taxable only 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; or
    • (ii) did not become a resident of that State solely for the purpose of rendering the services.

(2)

  • (a) Notwithstanding the provisions of paragraph (1) any pension paid by, or out of funds created by, a Contracting State or a local authority thereof to an individual in respect of services rendered to that State or authority in the discharge of functions of a governmental nature shall be taxable only in that State.
  • (b) However, such pension and other similar remuneration shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that other State.

(3) The provisions of Articles 16, 17, 18 and 19 shall apply to salaries, wages, pensions and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a local authority thereof.