DT6720.19 - DT: Estonia: double taxation agreement, Article 19: Government service

1. Remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof or an agency thereof or an entity wholly owned by such State, political subdivision or local authority to an individual in respect of services rendered to that State, subdivision, authority, agency or entity shall be taxable only in that State.
   
   
2. Notwithstanding the provisions of subparagraph (a) of this paragraph, 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.

3. Any pension paid by, or out of funds created by, a Contracting State or a political subdivision or a local authority thereof or an agency thereof or an entity wholly owned by such State, political subdivision or local authority to an individual in respect of services rendered to that State, subdivision, authority, agency or entity shall be taxable only in that State.
   
   
4. Notwithstanding the provisions of sub-paragraph (a) of this paragraph, such pension shall be taxable only in the other Contracting State if the the individual is a resident of and a national of that State.
   
   

3. The provisions of Articles 15, 16 and 18 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 or an agency thereof or an entity wholly owned by such State, subdivision or authority.