Article 20, GOVERNMENTAL FUNCTIONS
U.S. Income Tax Treaty — Technical Explanation - 1976 · 2026-10-03 edition · updated 2026-10-04 · United States
Under this Article, wages, salaries, and similar remuneration, including pensions, aMulties, or similar benefits, paid from public funds of one Contracting State to a citizen of that Contracting State, or to a citizen of a State other than a Contracting State who comes to the other Contracting State expressly for the purpose of being employed by the first-mentioned Contracting State, for labor or personal services per formed as an employee of the national government of that Contracting
State, or any agency thereof, in the discharge of functions of a govern mental nature will be exempt from tax by the other Contracting State. If the individual becomes a citizen of, or acquires immigrant status in, the other Contracting State, that other Contracting State may tax the individual without regard to this Article. See paragraphs (3) and (4)(b) of Article 6 (General Rules of Taxation). Remuneration or pensions paid in respect of services rendered in connection with any trade or business carried on by one of the Contracting States or any agency thereof will be treated the same as compensation received from a private employer, and the provisions of Articles 15 (Independent Personal Services), 16 (Dependent Personal Services) and 18 (Private Pensions and AMuities), as the case may be, will apply,
This Article applies only to remuneration paid out of public funds
by the national government of a Contracting State or its agencies.
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