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ARTICLE 19

Government Service

(1)

  • (a) Wages, salaries and other similar remuneration paid by a Contracting State or one of its political subdivisions or local entities to an individual in respect of services rendered to that State or to that subdivision or entity, shall be taxable only in that State.
  • (b) However, such wages, salaries and similar remunerations shall only be taxable in the other Contracting State, if the services are rendered in that State and the individual who is a resident of that State and:
    • (i) is a national of that State; or
    • (ii) did not become a resident of that State solely for the purpose of performing the services.

(2)

  • (a) Notwithstanding the provisions of paragraph (1) of the Article, pensions and similar remuneration paid directly by, or out of funds created by, a Contracting State or by one of its political subdivisions or local entities thereof, to an individual in respect of services rendered to that State or subdivision or entity, shall be taxable only in that State.
  • (b) However, such pensions and similar remunerations shall be taxable only in the other Contracting State, if the individual is a resident and national of that State.

(3) The provisions of Articles 15, 16, 17 and 18 of this Convention shall apply to wages, salaries, pensions and other similar remuneration in consideration of services rendered in connection with a business carried on by a Contracting State or by one of its political subdivisions or local authorities.