Direct Tax Avoidance Agreements

UAR (Egypt)

Article XX - Governmental functions - 1. Remuneration, including pensions, paid by, or out of funds, created by, a Contracting State or a political sub-division, or a local authority thereof, to any individual in respect of services rendered to that State or sub-division or local authority thereof in the discharge of functions of a governmental nature may be taxed in that State.

2. The provisions of paragraph (1) of this article shall also apply to remuneration including pensions, paid by the Central Bank, the Post Railways, Telephone and Telegraph, Radio and Television Organisations of the United Arab Republic and by the Reserve Bank of India, Postal Administration, the Public Railway Authorities and the All India Radio Organisation of India.

3. The provisions of articles XVI, XVII and XIX shall apply to remuneration or pensions in respect of services rendered in connection with any trade or business other than those mentioned in paragraph (2) carried on by any of the legal entities mentioned in this article