第18条 政府サービス
令和7年11月21日|p.24
左の本文を選ぶと、右側の官報原文画像で該当箇所を照合できます。
ARTICLE 18
GOVERNMENT SERVICE
1. (a) Salaries, wages and other similar remuneration paid by a Contracting State
or a political subdivision or local authority thereof to an individual in
respect of services rendered to that Contracting State or political
subdivision or local authority shall be taxable only in that Contracting
State.
(b) However, such salaries, wages and other similar remuneration shall be
taxable only in the other Contracting State if the services are rendered in
that other Contracting State and the individual is a resident of that other
Contracting State who:
(i)。0.0a national of that other Contracting State; or
(ii) did not become a resident of that other Contracting State solely for
the purpose of rendering the services.
2. (a) Notwithstanding the provisions of paragraph 1, pensions and other similar
remuneration paid by, or out of funds which are created by or to which
contributions are made by, a Contracting State or a political subdivision or
local authority thereof to an individual in respect of services rendered to
that Contracting State or political subdivision or local authority shall be
taxable only in that Contracting State.
(b) However, such pensions and other similar remuneration shall be taxable
only in the other Contracting State if the individual is a resident of, and a
national of, that other Contracting State.
3. The provisions of Articles 14,15,16 and17 shall apply to salaries, wages,
pensions, and other similar remuneration in respect of services rendered in connection
with a business carried on by a Contracting State or a political subdivision or local
authority thereof.
Payments which a student or business apprentice who is or was immediately
before visiting a Contracting State a resident of the other Contracting State and who is
present in the first-mentioned Contracting State solely for the purpose of his education or
training receives for the purpose of his maintenance, education or training shall not be
taxed in that Contracting State, provided that such payments arise from sources outside
that Contracting State. In the case of a business apprentice, the exemption provided by
this Article shall apply only for a period not exceeding one year from the date on which
he first begins his training in that Contracting State