1.
a) Salaries, wages and other similar remuneration, paid by a
Contracting State, one of its “Länder”, or one of their political
subdivisions or local authorities to an individual in respect of
services rendered to that State, “Land” or political subdivision
or local authority shall be taxable only in that State.
b) However, such salaries, wages and other similar remunera-
tion shall be taxable only in the other Contracting State if the
services are rendered in that State and the individual is a res-
ident of that State who:
(i) is a national of that State; or
(ii) did not become a resident of that State solely for the pur-
pose of rendering the services.
2.
a) Notwithstanding the provisions of paragraph 1, pensions and
other similar remuneration paid by, or out of funds created
by, a Contracting State, one of its “Länder”, or one of their
political subdivisions or local authorities to an individual in re-
spect of services rendered to that State, “Land” or political
subdivision or local 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.
3. The provisions of paragraphs 1 and 2 shall likewise apply
to salaries, wages, pensions and other similar remuneration paid
by a legal entity under public law which carries out functions of
a governmental nature if it is mutually agreed by the competent
authorities for this legal entity under public law.
4. The provisions of Articles 14, 15, 16, and 17 shall apply to
salaries, wages, pensions, and other similar remuneration in re-
spect of services rendered in connection with a business carried
on by a Contracting State, one of its “Länder”, or one of their po-
litical subdivisions or local authorities or another legal person un-
der the public law of that State.
5. The provisions of paragraphs 1 and 2 shall also apply to
salaries, wages, pensions, and other similar remuneration paid
to an individual in respect of services rendered to the Goethe In-
stitute and the German Academic Exchange Service (“Deutscher
Akademischer Austauschdienst”), or to other comparable insti-
tutions if mutually agreed by the competent authorities. Where
this remuneration is not taxed in the State of establishment of
the institution, Article 14 shall apply.
6. The provisions of paragraph 1 shall likewise apply in re-
spect of remuneration paid, under a development assistance
programm of a Contracting State, one of its “Länder”, or one of
their political subdivisions or local authorities, out of funds ex-
clusively supplied by that State, “Land”, political subdivision or
local authority, to a specialist or volunteer seconded to the other
Contracting State with the consent of that other State.