DT17618 - Spain: double taxation agreement, Article 19: Government service
(1) Remuneration, other than a pension, paid out of public funds of the United Kingdom or Northern Ireland or of the funds of any local authority in the United Kingdom to any individual in respect of services rendered to the Government of the United Kingdom or Northern Ireland or a local authority in the United Kingdom, shall be taxable only in the United Kingdom. However, such remuneration shall be taxable only in Spain if the services are rendered in Spain and the recipient is a resident of Spain who:
(a) is a national of Spain; or
(b) did not become a resident of Spain solely for the purpose of performing the services.
(2) Remuneration, other than a pension, paid by Spain or a political subdivision or a local authority thereof to any individual in respect of services rendered to the Government of Spain or a political subdivision or a local authority thereof, shall be taxable only in Spain. However, such remuneration shall be taxable only in the United Kingdom if the services are rendered in the United Kingdom and the recipient is a resident of the United Kingdom who:
(a) is a national of the United Kingdom; or
(b) did not become a resident of the United Kingdom solely for the purpose of performing the services.
(3) Any pension paid by, or out of funds created by, the United Kingdom or Northern Ireland or a local authority in the United Kingdom to any individual in respect of services rendered to the Government of the United Kingdom or Northern Ireland or a local authority in the United Kingdom shall be taxable only in the United Kingdom. However, such pensions shall be taxable only in Spain if the recipient is a national of and a resident of Spain.
(4) Any pension paid by, or out of funds created by, Spain or a political subdivision or a local authority thereof to any individual in respect of services rendered to Spain or a political subdivision or a local authority thereof shall be taxable only in Spain. However, such pensions shall be taxable only in the United Kingdom if the recipient is a national of and a resident of the United Kingdom.
(5) The provisions of Articles 15,16 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with any business carried on by a Contracting State (including in the case of the United Kingdom, any business carried on by the Government of Northern Ireland) or a political subdivision or a local authority thereof.
