DT2714 - DT: Australia: old agreement, Article 15: Governmental functions

This Agreement applies up to 5th April 2005 UK income tax and up to 30th June 2004 for Australian taxes. For later periods the new Agreement applies. This can be accessed via the page Tax Treaties – in force http://www.hmrc.gov.uk/international/in_force.htm.

(15)(1) Remuneration (other than pensions) paid by the Government of the Commonwealth or of any State of the Commonwealth to any individual for services rendered to that Government in the discharge of governmental functions shall be exempt from United Kingdom tax if the individual is not ordinarily resident in the United Kingdom or is ordinarily resident in the United Kingdom solely for the purpose of rendering those services.

(2) Remuneration (other than pensions) paid by the Government of the United Kingdom or the Government of Northern Ireland to any individual for services rendered to that Government in the discharge of governmental functions shall be exempt from Australian tax if the individual is not a resident of Australia or is resident in Australia solely for the purpose of rendering those services.

(3) This Article shall not apply to payments in respect of services rendered in connection with any trade or business carried on by a Government referred to in paragraphs (1) and (2) of this Article.