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ARTICLE 19

Government Service

(1)

  • (a) Wages, remuneration, other than pensions, paid by a Contracting State or one of its political subdivisions, or local authorities to an individual in respect of services rendered in that State, political subdivision or local authority, shall be taxable only in that Contracting State.
  • (b) However, such wages and 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) Any pension paid by, or out of funds created by, a Contracting State or by one of its political subdivisions, a local authority thereof to an individual in respect of services rendered to that Contracting State, local 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 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by a Contracting State or by one of its political subdivisions or local authorities.

(4) The provisions of paragraph (2) of this Article shall not affect the provisions of law in a Contracting State regarding the exemptions from tax of such pensions.