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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 18

Government Service

(1)

  • (a) Remunerations other than pensions paid by a state, political division or local authority to anyone for the services made for such state, division or local authority shall be taxable only in such state;
  • (b) However, such remuneration shall be taxable only in the other Contracting state if the services were rendered in such state and this individual was resident and national of this state and did not become a resident of that State solely for the purpose of rendering such services.

(2)

  • (a) Any pensions paid by a Contracting state, any political divisions or local authorities for the services rendered to such state, any political division or authority shall be taxable only in such state;
  • (b) However, such pension may be taxable only in the other Contracting state if it is given to a resident or a national of the other Contracting state in accordance with its applicable legislations.

(3) The provisions of Articles 15 and 16 of this Convention shall be applied to the pensions and remunerations rendered in consideration of services made in a Contracting state, any political division or local authority.