Document ID: chunk:federal_register_of_legislation:C2004A00692:schedule:45:p16
Version: federal_register_of_legislation:C2004A00692
Segment Type: schedule
Provision Reference: sch 45 (pt 16/20)
Character Range: 39549–42201

the other Contracting State shall be taxable only in the firstmentioned State.

Article 19
Government service

1 Remuneration, other than a pension or annuity, paid by a Contracting State or a political subdivision, local authority or administrative‑territorial unit of that State to any individual in respect of services rendered in the discharge of governmental functions shall be taxable only in that State. However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State and the recipient is a resident of that other State who:

       (a) has the citizenship of that State; or

       (b) did not become a resident of that State solely for the purpose of performing the services.

2 The provisions of paragraph 1 shall not apply to remuneration in respect of services rendered in connection with any trade or business carried on by a Contracting State or a political subdivision, local authority or administrative‑territorial unit of that State. In that case, the provisions of Article 15 or Article 16, as the case may be, shall apply.

Article 20
Students

Where a student, who is a resident of a Contracting State or who was a resident of that State immediately before visiting the other Contracting State and who is present in that other State solely for the purpose of the student's education for a period not exceeding seven years, receives payments from sources outside that other State for the purpose of the student's maintenance or education, those payments shall be exempt from tax in that other State.

Article 21
Income not expressly mentioned

1 Items of income of a resident of a Contracting State which are not expressly mentioned in the foregoing Articles of this Agreement shall be taxable only in that State.

2 However, any such income derived by a resident of a Contracting State from sources in the other Contracting State may also be taxed in that other State.

3 The provisions of paragraph 1 shall not apply to income, other than income from real property as defined in paragraph 2 of Article 6, derived by a resident of a Contracting State where that income is effectively connected with a permanent establishment or fixed base situated in the other Contracting State. In that case, the provisions of Article 7 or Article 14, as the case may be, shall apply.

Article 22
Source of income

1 Income, profits or gains derived by a resident of a Contracting State which, under any one or more of Articles 6 to 8, 10 to 19 and 21, may be taxed in the other Contracting State shall for the purposes of the law of that other Contracting State relating to its tax