GOVERNMENTAL FUNCTIONS. 1. Remuneration (other than a pension) paid by or out of public funds of a Contracting State or a political subdivision or local authority or statutory authority thereof to - (a) a citizen of that Contracting State; (b) an individual who is not a citizen of the other Contracting State and who goes to the other State solely in pursuance of his employment by the first- mentioned State, for services rendered to that State in the discharge of functions of a governmental nature shall be exempt from tax in the other State. 2. The provisions of paragraph 1 shall not apply to remuneration (other than a pension) paid in respect of services rendered in connection with any trade or business carried on by a Contracting State or a political subdivision or local authority or statutory authority thereof.
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Samples: Agreement for the Avoidance of Double Taxation, Agreement for the Avoidance of Double Taxation, Convention for the Avoidance of Double Taxation
GOVERNMENTAL FUNCTIONS. 1. Remuneration (other than a pension) including pensions paid by or out of public funds of a Contracting State or a political subdivision sub-division or local authority or statutory authority thereof to -
(a) a citizen of that Contracting State;
(b) an individual who is not a citizen of the other Contracting State and who goes to the other State solely in pursuance for the purpose of his employment being engaged by the first- first-mentioned State, for services rendered to that State in the discharge of functions of a governmental nature shall be exempt from tax in the other State.
2. The provisions of paragraph 1 shall not apply to remuneration (other than a pension) including pension paid in respect of services rendered in connection with any trade or business carried on by a Contracting State or a political subdivision sub-division or local authority or statutory authority thereof.
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Samples: Double Taxation Avoidance Agreement, Convention for the Avoidance of Double Taxation, Double Taxation Avoidance Agreement