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Norway - Sint Maarten Tax Treaty (as amended by 2009 protocol) — Orbitax Tax Hub

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 a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or 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 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) The provisions of Articles 15 and 16 shall apply to remuneration other than pensions in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof, other than those businesses referred to in paragraph (3) below.

(3) For the purpose of this Article services rendered to a Contracting State or to a political subdivision or local authority thereof shall include public postal, telecommunication, power and water supply services including such services rendered to a company wholly or almost wholly owned by that Contracting State.