GOVERNMENT SERVICE. (a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision, a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that State. (b) However, such 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 this Article shall not apply to any remuneration in respect of services rendered in connection with any trade or business carried on for purposes of profit.
Appears in 6 contracts
Samples: Double Taxation Agreement, Double Taxation Agreement, Double Taxation Agreement
GOVERNMENT SERVICE. (a) 1 Remuneration, other than a pension, paid by a Contracting State or a political subdivision, subdivision or a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that State.
(b) . 2 However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State 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 this Article shall not apply to any remuneration in respect of services rendered in connection with any trade or business carried on for purposes of profit.
Appears in 5 contracts
Samples: Double Taxation Agreement, Income Tax Agreement, Double Taxation Avoidance Agreement
GOVERNMENT SERVICE. (a) RemunerationSalaries, wages and other similar remuneration (other than a pension, pensions) paid by the Government of a Contracting State or a political subdivision, a local authority or a statutory body thereof to an individual in respect of services rendered to that State Government or subdivision or local authority or body shall be taxable only in that State.
(b) However, such remuneration payments shall be taxable only in the other Contracting State if the services are rendered in that other Contracting State and the individual is a resident of that other Contracting State who:
(i) is a national of that other Contracting State; or
(ii) did not become a resident of that other Contracting State solely for the purpose of rendering the services.
2. The provisions of this Article Articles 15, 16 and 17 shall not apply to any remuneration payments in respect of services rendered in connection with any trade or a business carried on for purposes of profitby a Government or a local authority referred to in paragraph 1.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion With Respect to Taxes on Income
GOVERNMENT SERVICE. (a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision, a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that State.
(b) However, such 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 this Article shall not apply to any remuneration in respect of services rendered in connection with any trade or business carried on for purposes of profit.
Appears in 4 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
GOVERNMENT SERVICE. (a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision, a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or subdivision, authority or body shall be taxable only in that State.
(b) However, such 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 this Article Articles 15 and 16 shall not apply to any remuneration in respect of services rendered in connection with any trade or a business carried on for purposes of profitby a Contracting State or a political subdivision, a local authority or a statutory body thereof.
Appears in 4 contracts
Samples: Double Taxation Agreement, Agreement for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement
GOVERNMENT SERVICE. (a) RemunerationSalaries, wages and other remuneration, other than a pension, paid by a Contracting State or a political subdivision, subdivision or a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that State.
(b) However, such salaries, wages and other 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 this Article Articles 14, 15 and 16 shall not apply to any salaries, wages and other remuneration in respect of services rendered in connection with any trade or a business carried on for purposes of profitby a Contracting State or a political subdivision or a local authority thereof.
Appears in 3 contracts
Samples: Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
GOVERNMENT SERVICE. (a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision, subdivision or a local authority or a statutory body thereof to an individual in respect of services rendered to that Contracting State or subdivision or authority or body shall be taxable only in that Contracting State.
(b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other Contracting State and the individual is a resident of that other Contracting State who:
(i) is a national of that other Contracting State; or
(ii) did not become a resident of that other Contracting State solely for the purpose of rendering the services.
2. The provisions of this Article Articles 15, 16 and 17 shall not apply to any remuneration in respect of services rendered in connection with any trade or a business carried on for purposes of profitby a Contracting State or a political subdivision or a local authority thereof.
Appears in 2 contracts
Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation
GOVERNMENT SERVICE. (a) 1. Remuneration, other than a pension, paid by, or out of funds created by a Contracting State or a political subdivision, subdivision or a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that Contracting State.
(b) 2. However, such 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 Contracting State; or
(ii) did not become a resident of that other Contracting State solely for the purpose of rendering the services.
23. The provisions of Articles 15, 16 and 18 of this Article Agreement shall not apply to any remuneration remunerations and pension in respect of services rendered in connection with any trade or a business carried on for purposes of profitby a Contracting State or a political subdivision or a local authority thereof.
Appears in 1 contract
Samples: Income and Capital Tax Agreement
GOVERNMENT SERVICE. (a) Remuneration, other than a pension, paid by a Contracting State State, or a political subdivision, or a local authority authority, or a statutory body thereof to an individual in respect of dependent personal services rendered to that State or subdivision or State, subdivision, authority or body shall be taxable only in that State.
(b) However, such remuneration shall be taxable only in the other Contracting State of which the individual is a resident if the services are rendered in that other State and the individual is a resident of that other State whoindividual:
(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 this Article Articles 15 and 16 shall not apply to any remuneration in respect of services rendered in connection with any trade or a business carried on for purposes of profitby a Contracting State, or a political subdivision, or a local authority, or a statutory body thereof.
Appears in 1 contract
GOVERNMENT SERVICE. (a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision, or administrative subdivision or a local authority or a statutory body thereof to an any individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that State.
(b) However, such 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:
(i1) is a national of that other State not being a national of the first-mentioned State; , or
(ii2) did not become a resident of that other State solely for the purpose of rendering the services.
2. The provisions of this Article shall not apply to any remuneration in respect of services rendered in connection with any trade or business carried on for purposes of profit.
Appears in 1 contract
GOVERNMENT SERVICE. (a) RemunerationSalaries, wages and other similar remuneration, other than a pension, paid by a Contracting State or a political subdivision, subdivision or a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that State.
(b) However, such salaries, wages and other 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 this Article shall not apply to any remuneration in respect of services rendered in connection with any trade or business carried on for purposes of profit.
Appears in 1 contract
GOVERNMENT SERVICE. (a) Remuneration, other than a pension, paid by by, or out of public funds of, a Contracting State or a political subdivision, subdivision or a local authority or a statutory body thereof to an individual in respect of services rendered to that State or subdivision or authority or body shall be taxable only in that State.
(b) However, such 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 this Article Articles 14 (Dependent Personal Services) and 15 (Directors Fees) shall not apply to any remuneration in respect of services rendered in connection with any trade or a business carried on for purposes of profitby a Contracting State or a political subdivision or a local authority thereof.
Appears in 1 contract