ARTICLE 19
Government Service
(1) Remuneration (other than a pension or annuity) paid by a Contracting State or a political sub‑‑division or a local authority thereof to any individual in respect of services rendered in the discharge of governmental functions shall be taxable only in that State. However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the recipient is a resident of that State who:
(a) is a citizen of that State; or
(b) did not become a resident of that State solely for the purpose of performing the services.
(2) The provisions of paragraph (1) shall not apply to remuneration in respect of services rendered in connection with any trade or business carried on by one of the Contracting States or a political sub‑‑division or a local authority thereof. In such a case the provisions of Articles 15 and 16 shall apply.
Australia / Canada · Australia–Canada 1980 Convention
ARTICLE 19 · Government Service
English · original source edition
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Australia / Canada; International Tax Agreements Act 1953, compilation prepared 25 March 2010, Schedule 3; source scope International Tax Agreements Act 1953, compilation prepared 25 March 2010, Schedule 3; edition 1980 base Convention; 2010 statutory source edition; 2002 Protocol retained separately, not incorporated; article 19; English; unreviewed source text, current applicability unverified; /editions/au-ca-1980-convention-official-schedule-v1/en/articles/article-19/
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International Tax Agreements Act 1953, compilation prepared 25 March 2010, Schedule 3
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Complete Schedule3 base1980 Convention, ending before separately printed Schedule3A2002protocol; parent2010volume incomplete.
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- International Tax Agreements Act 1953, compilation prepared 25 March 2010, Schedule 3
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Source language clause (not a claim of supplied translations): DONE in Canberra on the twenty‑‑first day of May 1980 in the English and French languages, the two versions being equally authentic.
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- 1980-05-21
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