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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) Remuneration other than pensions paid by a Contracting State or by one of its administrative or political subdivisions or local authorities, to an individual, in consideration of services rendered to that State, administrative or political subdivision or local authority, 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 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) The provisions of Articles 15, 16 and 18 shall apply to remuneration as well as to pensions paid in respect of services rendered in connection with a business carried on by a Contracting State or by one of its administrative or political subdivisions or local authorities.