DT7118 - DT: Fiji: double taxation agreement, Article 19: Government functions


(1) Remuneration, including pensions, paid by the Government of a Contracting State to any individual in respect of services rendered to that Government in the discharge of governmental functions shall be exempt from tax in the other Contracting State if the individual is not ordinarily resident in that other State or (where the remuneration is not a pension) is ordinarily resident in that other State solely for the purpose of rendering those services.

(2) The provisions of paragraph (1) of this Article shall not apply to payments in respect of services rendered in connection with any trade or business carried on by the Governments of either of the Contracting States for the purposes of profit.