(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.