This Agreement applies in the UK up to 31 March 2003 (CT) and
2002/3 (IT) and in South Africa up to 31 December 2002. For later
periods see “New treaties/protocols in force” on the
left-hand bar on the DT manual.
(1) Remuneration (other than pensions) paid by a Contracting
State to any individual for services rendered to that Contracting
State 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 State or is ordinarily resident in that
State solely for the purpose of rendering those services.
(2) Any pension paid by a Contracting State to any individual
for services rendered to that Contracting State in the discharge of
governmental functions shall be exempt from tax in the other
Contracting State, in so far as the remuneration for those services
was exempt from tax in that State under paragraph (I) of this
Article or would have been so exempt if this Convention had been in
force at the time when the remuneration was paid.
(3) The provisions of this Article shall not apply to
payments in respect of services rendered in connection with any
trade or business carried on by either of the Contracting States
for purposes of profit.
(4) For the purposes of this Article, the term `Contracting
State`, in the case of South Africa, includes the Administrations
of the Provinces of South Africa.
