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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 19

Public Functions

(1)

  • (a) Any remuneration, other than pensions, paid by a Contracting State or by one of its political subdivisions or local entities, to an individual in respect of services rendered to that State, political subdivision or local entity 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 if 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 State solely for the purpose of rendering such services.

(2)

  • (a) Any pension paid by a Contracting State or by any one of its political subdivision or local entities, whether directly or by drawing on funds created for that purpose, to an individual in respect of services rendered to that State or a political subdivision or local entity thereof shall be taxable only in that State.
  • (b) However, such pensions shall be taxable only in the other Contracting State if the individual is a resident of that State.

(3) The provisions of Articles 15, 16 and 18 shall apply to any remuneration or pension paid in respect of services rendered in connection with an industrial or commercial activity carried on by a Contracting State or by one of its political subdivisions or local entities.