Article 19 - Government Services - International Taxation - Income Tax

Article 19 - Government Services As per OECD Model Tax Convention Taxability of Salaries, Wages, and other similar remuneration a) Salaries, wages and other similar remuneration paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. b) However, such salaries, wages and other similar remuneration 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; or (ii) did not become a resident of that State solely for the purpose of rendering the services. [ Para 1 of Article 19 ] Taxability of Pension and other similar remuneration a) Pensions and other similar remuneration paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State. b) However, such pensions and other similar remuneration shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State. [ Para 2 of Article 19 ] Applicability of other Articles The provisions of Articles 15, 16, 17, and 18 shall apply to salaries, wages, pensions, and other similar remuneration in respect of services rendered in connection with a business carried on by a Contracting State or a political subdivision or a local authority thereof. [ Para 3 of Article 19 ] As per UN Model Tax Convention Article 19 of the United Nations Model Convention reproduces Article 19 of the OECD Model Convention.