DT4630.18 - Canada: double taxation agreement, Article 18: Government service

(1)

(a) Remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to any individual in respect of services rendered to that State or subdivision or local authority thereof shall be taxable only in that State.

(b) However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the recipient 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 performing the services.

(2) This Article shall not apply to remuneration in respect of services rendered in connection with any trade or business carried on by one of the Contracting States or a political subdivision or a local authority thereof.

(3) In this Article, the term `political subdivision` shall, in relation to the United Kingdom, include Northern Ireland.