Direct Tax Avoidance Agreements

Taipei

Article 19

GOVERNMENT SERVICE

1.(a) Salaries, wages and other similar remuneration, other than a pension, paid by a territory or a sub-division or a local authority thereof to an individual in respect of services rendered to that territory or sub-division or authority shall be taxable only in that territory.

(b) However, such salaries, wages and other similar remuneration shall be taxable only in the other territory if the services are rendered in that territory and the individual is a resident of that territory who:

  (i)  is a national of that territory; or

 (ii)  did not become a resident of that territory solely for the purpose of rendering the services.

2.(a) Any pension paid by, or out of funds created by, a territory or a sub-division or a local authority thereof to an individual in respect of services rendered to that territory or sub-division or authority shall be taxable only in that territory.

(b) However, such pension shall be taxable only in the other territory if the individual is a resident of, and a national of, that other territory.

3. The provisions of Articles 15, 16, 17 and 18 shall apply to salaries, wages and other similar remuneration and to pensions in respect of services rendered in connection with a business carried on by a territory or a sub-division or a local authority thereof.