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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

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 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) of this Article, pensions and other similar remuneration paid by a Contracting State or a local authority thereof, either directly or from the funds created by a Contracting State or a local authority thereof, to an individual in respect of services rendered to that State or authority shall be taxable only in that State.
  • (b) However, such pensions 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 State.

(3) The provisions of Articles 15, 16, 17, and 18 of this Convention shall apply to salaries, wages, pensions and other similar remuneration paid in respect of services rendered in connection with an industrial or commercial activity carried out by a Contracting State or a local authority thereof.