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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

Government Service

(1)

  • (a) Salaries, wages and other similar payments, other than pensions, paid by a Contracting State or a local authority thereof to an individual in respect of services rendered to that State or authority shall be taxable only in that State.
  • (b) However, such salaries, wages and other similar payments 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;
    • (ii) has not become a resident of that State solely for the purpose of rendering the services.

(2)

  • (a) Pensions paid by a Contracting State or local authority or drawn from funds constituted for the purpose, to an individual, in respect of services rendered to that State, shall be taxable only in that State.
  • (b) However, such pensions 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 14, 15 and 18 shall apply to remuneration and pensions paid in respect of services rendered in connection with a commercial activity carried on by a Contracting State or one of its local authorities.

(4) The contents of paragraph (2) of this Article shall be without prejudice to the provisions of the law of a Contracting State insofar as the tax exemption of retirement pensions is concerned.