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(a)Salaries, wages and other similar remuneration, other than a pension or annuity, paid by an authority administering a territory or a subdivision thereof, or by a local authority of that territory to an individual in respect of services rendered in the discharge of public or administrative functions on behalf of such an authority shall be taxable only in that territory.
(b)Notwithstanding the provisions of sub-paragraph (a) of this paragraph, such salaries, wages and other similar remuneration shall be taxable only in the other territory if the services are rendered in that territory and the individual is a resident of that territory who:
(i)is a citizen or national of that territory; or
(ii)did not become a resident of that territory solely for the purpose of rendering the services.
(2) (a) Any pension or annuity paid by, or out of funds created by, a territory or a political subdivision or a local authority thereof to an individual in respect of services rendered to that territory or subdivision or authority shall be taxable only in that territory.
(b)Notwithstanding the provisions of sub-paragraph (a) of this paragraph, such pension or annuity shall be taxable only in the other territory if the individual is a resident of, and a citizen or national of, that territory.
(3) The provisions of Articles 15, 16, 17 and 18 of this Agreement shall apply to salaries, wages and other similar remuneration, and to pensions or annuities, in respect of services rendered in connection with a business carried on by any authority referred to in paragraph (1) of this Article.
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