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- a)Remuneration, other than a pension, paid 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 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:
- (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.
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- The provisions of Articles 15 and 16 shall apply to remuneration other than 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, other than those businesses referred to in paragraph 3 below.
- 3
- For the purpose of this Article services rendered to a Contracting State or to a political subdivision or local authority thereof shall include public postal, telecommunication, power and water supply services including such services rendered to a company wholly or almost wholly owned by that Contracting State.