AUSTRALIAN TAX TREATIES

Philippine Agreement  

AGREEMENT BETWEEN THE GOVERNMENT OF AUSTRALIA AND THE GOVERNMENT OF THE REPUBLIC OF THE PHILIPPINES FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME  

CHAPTER III - TAXATION OF INCOME  

ARTICLE 19   Government Service  

(1)  
Remuneration (other than a pension) paid by a Contracting State or a political subdivision of that State or a local authority of that State to any individual in respect of services rendered in the discharge of governmental functions shall be taxable only in that State. However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that State and the recipient is a resident of that State who -


(a) is a citizen or national of that State; or


(b) did not become a resident of that State solely for the purpose of performing the services.

(2)  
The provisions of paragraph (1) shall not apply to remuneration in respect of services rendered in connection with any trade or business carried on by one of the Contracting States or a political sub-division of one of the States or a local authority of one of the States. In such a case the provisions of Article 15 and 16 shall apply.




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