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- a)Remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof, or an agency or wholly owned entity of such State, subdivision or authority, to an individual in respect of dependent personal services rendered to that State or subdivision or authority, agency or entity, may be taxed in that State.
- b)However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the individual is a resident of that State who:
- 1.is a national of that State; or
- 2.did not become a resident of that State solely for the purpose of rendering the services.
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- a) Any pension paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereof, or an agency or wholly owned entity of such State, subdivision or authority, to an individual in respect of dependent personal services rendered to that State or subdivision or authority, agency or entity, may be taxed 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.
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- The provisions of Articles 15, 16 and 18 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, or an agency or wholly owned entity of such State, subdivision or authority.
