DT4167 - DT: Bulgaria: double taxation agreement, Article 18: Government service
- 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.
- 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.
- Any pension paid by, or out of funds created 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.
- However such pension shall be taxable only in the other
Contracting State if the individual is a resident of, and a
national of, that State.
- The provisions of Articles 14, 15 and 17 of this Convention
shall apply to 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.
