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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 21

Government Service

(1)

  • (a) Remuneration, other than pensions, paid by a Contracting State or one of its administrative subdivisions or local authorities to an individual for services rendered to that State or subdivision or authority shall be taxable in that State.
  • (b) However, such remuneration may be taxed in the other Contracting State if the services are rendered in that State and if the individual is a resident of that State, and:
    • (i) is a national of that State or of a third party State; or
    • (ii) has not become a resident of that State solely for the purpose of rendering such services.

(2) The provisions of Articles 17 and 18 of this Convention shall apply to remuneration other than pensions paid in respect of services rendered in connection with an industrial or commercial activity carried on by a Contracting State or one of its administrative subdivisions or local authorities.