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ARTICLE 19

U.S. Income Tax Treaty — australia tax treaty documents: austtech.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Governmental Remuneration

This Article provides that remuneration, including pensions, paid by one of the Contracting States or a political subdivision, local authority or agency thereof to a citizen of that State for the performance of governmental functions is exempt from tax by the other State. If such remuneration is paid to an individual who is a resident, but not a citizen, of the employing State, whether it may be taxed by the other Contracting State is determined in accordance with the provisions of Articles 14 (Independent Personal Services), 15 (Dependent Personal Services), 17 (Entertainers) or 18 (Pensions, Annuities, Alimony and Child Support), as the case may be. If such remuneration is paid by one of the States to an individual who is a resident of the other State (or by Australia to a citizen of the United States), it may be taxed by that other State (or by the United States in the case of U.S. citizens) in accordance with paragraph 3 of Article 1 (Personal Scope). If such remuneration is paid to an individual who is not a resident of either State (and is not a citizen of the United States), it is not covered by this Convention.

Whether functions are of a governmental nature is determined by reference to the concept of a governmental function in the State in which the income arises.

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▸Contents — U.S. Income Tax Treaty — australia tax treaty documents: austtech.pdf
U.S. Income Tax Treaty — australia tax treaty documents: austtech.pdf

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