- 1
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- a)Salaries, wages and other similar remuneration, other than a pension, paid by the Government of a Contracting Party or a political subdivision or a local authority thereof to an individual in respect of services rendered to that Contracting Party or subdivision or authority shall be taxable only in that Contracting Party.
- b)However, such salaries, wages and other similar remuneration shall be taxable only in the other Contracting Party if the services are rendered in that Contracting Party and the individual is a resident of that Contracting Party who:
- (i)in the case of the Netherlands, is a national thereof and in the case of the Hong Kong Special Administrative Region, has the right of abode therein; or
- (ii)did not become a resident of that Contracting Party solely for the purpose of rendering the services.
- 2
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- a)Any pension (including a lump sum payment) paid by, or out of funds contributed to or created by, the Government of a Contracting Party or a political subdivision or a local authority thereof to an individual in respect of services rendered to that Contracting Party or subdivision or authority shall be taxable only in that Contracting Party.
- b)However, such pension (including a lump sum payment) shall be taxable only in the other Contracting Party to the extent that the services were rendered in that Contracting Party under the circumstances as described under subparagraph (b) of paragraph 1.
- 3
- The provisions of the preceding paragraphs of this Article shall not apply to salaries, wages and other similar remuneration, or to pensions (including a lump sum payment), in respect of services rendered in connection with a business carried on by the Government of a Contracting Party or a political subdivision or a local authority thereof. In that case, the provisions of Articles 14, 15, 16 and 17, as the case may be, shall apply.
