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ARTICLE 19

Government Services

(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 Contracting State or one of its 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 Contracting State solely for the purpose of rendering such services.

(2)

  • (a) Pensions paid by a Contracting State or one of its political subdivisions or local authorities, whether directly or by drawing upon funds created for that purpose, to an individual in respect of services rendered in that State or its political subdivision or local authority, shall be taxable only in that State;
  • (b) However, such pensions shall also be taxed in the other Contracting State if the individual is a resident and national of that State.

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