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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

Governmental Service

(1)

  • (a) Salaries, wages and other remuneration paid by a Contracting State or by one of its political subdivisions or local authorities to an individual in respect of services rendered to that State, political subdivision or local authority, shall be taxable only in that Contracting State.
  • (b) However, such salaries, wages and other 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)

  • (a) Pensions paid by a Contracting State or by one of its political subdivisions or local authorities to an individual, either directly or out of funds created for that purpose, in respect of services rendered to that State, subdivision or authority, shall be taxable only in that State.
  • (b) However, such pension shall be taxable only in the other Contracting State if the individual is a resident and a national of that State.

(3) The provisions of Articles 15, 16, 17 and 18 shall apply to salaries, wages and other remuneration paid in respect of services rendered in connection with an industrial or commercial activity carried on by a Contracting State or by one of its political subdivisions or local authorities.