ARTICLE 19
Remuneration and Pensions in Respect of Government Service
1. a) Remuneration, other than a pension, paid by a
Contracting state or a political sub-division or a local
authority thereof to an individual in respect of services
rendered to that state or sub-division or authority 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
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.
2. a) Any pension 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 pension 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 Articles 16 (Dependent Personal
Services), 17 (Directors' Fees), 18 (Income Earned by
Entertainers and Athletes) and 20 (Private Pensions, Annuities,
Alimony and Child Support) shall apply to remuneration and
pensions 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.