(1)

• (a) Salaries, wages and other similar remunerations, other than a pension, paid by a Contracting State 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 salaries, wages and other similar remunerations shall be taxable only in the other Contracting State if the services are rendered in that Contracting State and the individual is a resident of that Contracting State who:
  • (i) is a national of that Contracting State; or
  • (ii) did not become a resident of that Contracting 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 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 other Contracting State.

(3) The provisions of Articles 15, 16, 17 and 18 of this Agreement shall apply to salaries, wages and other similar 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.