Article 19 - Government Service - Canada

ARTICLE 19 GOVERNMENT SERVICE 1. (a) Salaries, wages and similar remuneration, other than a pension, paid by a Contracting State or a political sub-division or a local authority thereof to an individual in respect of services rendered to that State or sub-division or authority, in any other State (including the other Contracting State) shall be taxable only in the first-mentioned State. (b) However, such salaries, wages or similar remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State and the individual is a resident of that other State who: (i) is a national of that other State; or (ii) did not become a resident of that other State solely for the purpose of rendering the services. 2. The provisions of paragraph 1 shall not apply to salaries, wages and similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political sub-division or a local authority thereof.