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CHAPTER 1 - General Provisions
CHAPTER 2 - Taxation of Income
CHAPTER 3 - Inheritance Tax
CHAPTER 4 - Registration Fees Other than Inheritance Tax-Stamp Duty
CHAPTER 5 - Administrative Assistance
CHAPTER 6 - Special Provisions
CHAPTER 7 - Transitional Provisions
CHAPTER 8 - Final Provisions
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.


Government Service

(1) Remuneration, including pensions, paid by a Member State or one of its political sub divisions or local authorities, whether directly or by drawing upon funds set up for that purpose, to an individual in respect of services rendered to that State or that sub division or authority in the exercise of functions of a public nature, shall be taxable only in that State.

However, such remuneration shall be taxable only in the other Member States if the services are rendered in these other States and if the individual receiving them is a resident of these other States who:

  • (1) possesses the nationality of these other States, or;
  • (2) has not become a resident of these other States for the sole purpose of rendering the services.

(2) The provisions of articles 16, 17, 18 and 19 of this Regulation shall apply to remunerations paid in respect of services rendered in the scope of a commercial or industrial activity carried out by one of the Member States or one of its local authorities.