Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 28
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34Austria
an individual for services performed for the pay
These exemptions do not apply to income or
ing governmental body are exempt from U.S. in
pensions for services performed in connection
Wages, salaries, similar income, and pensions
come tax unless the recipient is both a resident
with a business carried on by the People's Re
and annuities paid from public funds of Austria,
and national of the United States.
public of China or its subdivisions or local au
its political subdivisions, or its local authorities,
thorities.
to citizens of Austria for performing governmen
However, these exemptions do not apply to
tal functions as an employee are exempt from
Commonwealth of
payments for services performed in connection
U.S. tax.
Independent States (C.I.S.)
with a business carried on by Belgium, its politi
cal subdivisions, or local authorities.
However, this exemption does not apply to
Wages, salaries, and similar income paid by the
payments for services performed in connection
C.I.S. or a member of the C.I.S. to its citizens
Bulgaria
with a trade or business carried on by Austria or
for personal services performed as an em
its political subdivisions or local authorities.
ployee of a governmental agency or institution
Wages, salaries, and similar income, other than
of the C.I.S. or a member of the C.I.S. (exclud
a pension, paid by Bulgaria, its political subdivi
Bangladesh
ing local government employees) in the dis
sions, or local authorities to an individual for
charge of governmental functions are exempt
services performed for the paying governmental
from U.S. income tax. For this purpose, persons
Income, other than a pension, paid by Bangla
body are exempt from U.S. income tax. How
engaged in commercial activities are not con
desh, its political subdivisions, or local authori
ever, the exemption does not apply if the serv
sidered engaged in the discharge of govern
ties to an individual for services performed for
ices are performed in the United States by a
mental functions.
the paying governmental body is exempt from
resident of the United States who either:
U.S. income tax. However, the exemption does
Is a U.S. national, or
not apply if the services are performed in the
Cyprus
Did not become a U.S. resident only to
United States by a resident of the United States
perform the services.
who either:
Wages, salaries, and similar income, including
Is a U.S. citizen, or
pensions, annuities, and similar benefits, paid
Pensions paid by, or out of funds created
Did not become a U.S. resident only to
from public funds of Cyprus to a citizen of Cy
by, Bulgaria, its political subdivisions, or local
perform the services.
prus for labor or personal services performed
authorities for services performed for Bulgaria,
as an employee of Cyprus in the discharge of
its political subdivisions, or local authorities to
Pensions paid from the public funds of Ban
governmental functions are exempt from U.S.
an individual for services performed for the pay
gladesh, its political subdivisions, or local au
income tax.
ing governmental body are exempt from U.S. in
thorities for services performed for Bangladesh,
come tax unless the recipient is both a resident
its political subdivisions, or local authorities to
Czech Republic
and national of the United States.
an individual for services performed for the pay
ing governmental body are exempt from U.S. in
Income, including a pension, paid from the pub
However, these exemptions do not apply to
come tax unless the recipient is both a resident
lic funds of the Czech Republic, its political sub
payments for services performed in connection
and citizen of the United States.
divisions, or local authorities to a Czech citizen
with a business carried on by Bulgaria, its politi
for services performed in the discharge of gov
cal subdivisions, or local authorities.
This exemption does not apply to income or
ernmental functions is exempt from U.S. in
pensions for services performed in connection
come tax. This exemption does not apply to in
Canada
with a business carried on by Bangladesh, its
come paid for services performed in connection
political subdivisions, or local authorities.
with a business carried on by the Czech Repub
Wages, salaries, and similar income (other than
lic, its political subdivisions, or local authorities.
pensions) paid by Canada or by a Canadian po
Barbados
litical subdivision or local authority to a citizen of
Denmark
Canada for performing governmental functions
Income, including a pension, paid from the pub
are exempt from U.S. income tax. This exemp
lic funds of Barbados, or its political subdivi
Income, other than a pension, paid from public
tion does not apply, however, to payments for
sions or local authorities, to a citizen of Barba
funds of Denmark, its political subdivisions, or
services performed in connection with a trade
dos for performing governmental functions is
local authorities to an individual for services
or business carried on by Canada or its political
exempt from U.S. income tax.
performed for the paying governmental body in
subdivisions or local authorities.
the discharge of governmental functions is ex
However, this exemption does not apply to
empt from U.S. income tax. However, the ex
Also see Publication 597, Information on the
payments for services in connection with a busi
emption does not apply if the services are per
United States–Canada Income Tax Treaty.
ness carried on by Barbados or its political sub
formed in the United States by a resident of the
divisions or local authorities.
United States who either:
China, People's Republic of
Is a U.S. national, or
Belgium
Did not become a U.S. resident only to
Income, other than a pension, paid by the Peo
perform the services.
ple's Republic of China or its political subdivi
Wages, salaries, and similar income, other than
sions or local authorities to an individual for
a pension, paid by Belgium, its political subdivi
Pensions paid from the public funds of Den
services performed for the paying governmental
sions, or local authorities to an individual for
mark, its political subdivisions, or local authori
body is exempt from U.S. income tax. However,
services performed for the paying governmental
ties for services performed for Denmark are ex
the exemption does not apply to payments for
body is exempt from U.S. income tax. However,
empt from U.S. income tax unless the recipient
services performed in the United States by a
the exemption does not apply if the services are
is a resident and a national of the United States.
resident of the United States who either:
performed in the United States by a resident of
Is a U.S. citizen, or
the United States who either:
These exemptions do not apply to income or
Did not become a U.S. resident only to
Is a U.S. national, or
pensions for services performed in connection
perform the services.
Did not become a U.S. resident only to
with a trade or business carried on by Denmark,
perform the services.
its political subdivisions, or local authorities.
Pensions paid by the People's Republic of
Pensions paid by, or out of funds created
China for services performed for China are ex
by, Belgium, its political subdivisions, or local
empt from U.S. income tax unless the recipient
authorities for services performed for Belgium,
is both a citizen and a resident of the United
its political subdivisions, or local authorities to
States.
Page 28
Publication 901 (September 2016)
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