Article 19 - Government payments - Brazil

ARTICLE 19 GOVERNMENT PAYMENTS 1. Remuneration not including pensions, paid by a Contracting State, a political sub-division or a local authority thereof to an individual in respect of services rendered to that State, to a political sub-division or local authority shall be taxable only in that State. However, such remuneration shall be taxable only in the Contracting State of which the recipient is a resident if the services are rendered in that State and the recipient of the remuneration is a resident of that State who: (a) is a national of that State, or (b) did not become a resident of that State solely for the purpose of performing the services. 2. Pensions paid by, or out of funds created by, a Contracting State, a political sub-division or a local authority thereof to an individual in respect of services rendered to that State, to a political sub-division or a local authority thereof may be taxed in that State. 3. The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions paid in respect of services rendered in connection with any business carried on by a Contracting State, a political sub-division or a local authority thereof.