Document ID: chunk:federal_register_of_legislation:C2024C00814:schedule:1:p15
Version: federal_register_of_legislation:C2024C00814
Segment Type: schedule
Provision Reference: sch 1 (pt 15/31)
Character Range: 121179–123845

However, such salaries, wages and other similar remuneration shall be taxable only in the other territory if the services are rendered in that other territory and the recipient is a resident of that other territory who:
         (a) is a citizen or national of that territory; or
         (b) did not become a resident of that territory solely for the purpose of performing the services.

2. The provisions of paragraph 1 shall not apply to salaries, wages and other similar remuneration in respect of services rendered in connection with any trade or business carried on by any authority referred to in paragraph 1. 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 territory or who was a resident of that territory immediately before visiting the other territory and who is temporarily present in that other territory solely for the purpose of the student's education, receives payments from sources outside that other territory for the purpose of the student's maintenance or education, those payments shall be exempt from tax in that other territory.

Article 21
Other income

1. Items of income of a resident of a territory, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that territory.

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

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 territory where that income is effectively connected with a permanent establishment or fixed base situated in the other territory. In that case, the provisions of Article 7 or Article 14, as the case may be, shall apply.

Article 22
Methods of elimination of double taxation

Subject to the provisions of the law of a territory from time to time in force relating to the allowance of a credit against tax payable in that territory of tax paid outside that territory (which shall not affect the general principle of this Article), tax paid under the law of the other territory and in accordance with this Agreement, whether directly or by deduction, in respect of income derived by a person who is a resident of the first‑mentioned territory from sources in the other territory shall be allowed as a credit against tax payable in the first‑mentioned territory in respect of that income. The amount of credit, however, shall not exceed the amount of the tax in the first‑mentioned territory on that