Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 29
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34Egypt
to an individual in the United States for services
These exemptions do not apply to income or
performed for France (or for a local authority of
pensions for services performed in connection
Wages, salaries, and similar income, including
France) in the discharge of governmental func
with a trade or business carried on by Hungary
pensions, annuities, and similar benefits, paid
tions is exempt from U.S. tax. This exemption
or its subdivisions.
from public funds of the Arab Republic of Egypt
does not apply to a person who is both a resi
to a citizen of Egypt (or to a citizen of another
dent and citizen of the United States or a green
Iceland
country who comes to the United States specifi
card holder.
cally to work for the Government of Egypt) for
Wages, salaries, and similar income, other than
labor or personal services performed as an em
This exemption does not apply to any in
a pension, paid by Iceland, its political subdivi
ployee of the national Government of Egypt, or
come paid because of services (or past serv
sions, or local authorities to an individual for
any of its agencies, in the discharge of govern
ices) performed in connection with a business
services performed for the paying governmental
mental functions are exempt from U.S. income
carried on by the French Government (or a local
body are exempt from U.S. income tax. How
tax.
authority thereof).
ever, the exemption does not apply if the serv
ices are performed in the United States by a
This exemption does not apply to U.S. citi
resident of the United States who either:
Germany
zens or to alien residents of the United States.
Is a U.S. national, or
The exemption also does not apply to payments
Did not become a U.S. resident only to
Wages, salaries, and similar income, other than
for services performed in connection with a
perform the services.
a pension, paid by Germany, its political subdi
trade or business carried on by Egypt or any of
visions, local authorities, or instrumentalities to
its agencies.
an individual for services performed for the pay
Pensions paid by, or out of funds created
ing governmental body is exempt from U.S. in
by, Iceland, its political subdivisions, or local au
Estonia
come tax. However, the exemption does not
thorities for services performed for Iceland, its
apply if the services are performed in the United
political subdivisions, or local authorities to an
Income, other than a pension, paid by or from
States by a resident of the United States who
individual for services performed for the paying
public funds of Estonia, its political subdivi
either:
governmental body are exempt from U.S. in
sions, or local authorities to an individual for
Is a U.S. national, or
come tax unless the recipient is both a resident
services performed as an employee for the pay
Did not become a U.S. resident only to
and national of the United States.
ing governmental body in the discharge of gov
perform the services.
ernmental functions is exempt from U.S. in
However, these exemptions do not apply to
come tax. However, the exemption does not
Pensions paid by, or out of funds created
payments for services performed in connection
apply if the services are performed in the United
by, Germany, its political subdivisions, local au
with a business carried on by Iceland, its politi
States by a resident of the United States who
thorities, or instrumentalities for services per
cal subdivisions, or local authorities.
either:
formed for the paying governmental body are
Is a U.S. citizen, or
exempt from U.S. income tax unless the recipi
India
Did not become a U.S. resident only to
ent is both a resident and a national of the Uni
perform the services.
ted States.
Income, other than a pension, paid by India, its
political subdivisions, or local authorities to an
Pensions paid by or from the public funds of
This exemption does not apply to income or
individual for services performed for the paying
Estonia, its political subdivisions, or local au
pensions for services performed in connection
governmental body is exempt from U.S. income
thorities for services performed for Estonia are
with a business carried on by Germany, its polit
tax. However, the exemption does not apply if
exempt from U.S. income tax unless the recipi
ical subdivisions, local authorities, or instrumen
the services are performed in the United States
ent is both a resident and citizen of the United
talities.
by a U.S. resident who either:
States.
Is a U.S. citizen, or
Did not become a U.S. resident only to
Greece
Finland
perform the services.
Wages, salaries, and similar income and pen
Income, other than a pension, paid by Finland,
sions paid by Greece or its subdivisions to indi
Pensions paid by India for services per
its political subdivisions, statutory bodies, or lo
viduals living in the United States for services
formed for India are exempt from U.S. tax un
cal authorities to an individual for services per
rendered to Greece or its subdivisions are ex
less the individual is both a resident and citizen
formed for the paying governmental body is ex
empt from U.S. income tax. This exemption
of the United States.
empt from U.S. income tax. However, the
does not apply to citizens of the United States
exemption does not apply to payments for serv
or alien residents of the United States.
These exemptions do not apply to income or
ices performed in the United States by a U.S.
pensions for services performed in connection
resident who either:
Hungary
with a business carried on by India, its subdivi
Is a U.S. citizen, or
sions, or local authorities.
Did not become a U.S. resident only to
Income (other than a pension) paid by the Re
perform the services.
public of Hungary or its political subdivisions for
Indonesia
labor or personal services performed for the
Pensions paid by Finland for services per
paying governmental body is exempt from U.S.
formed for Finland are exempt from U.S. in
Income, other than a pension, paid by Indone
tax. However, the exemption does not apply to
come tax unless the recipient is a resident and
sia, its political subdivisions, or local authorities
payments for services performed in the United
citizen of the United States.
to an individual for services performed for the
States by a resident of the United States who
paying governmental body is exempt from U.S.
either:
These exemptions do not apply to income or
income tax. However, the exemption does not
Is a U.S. citizen, or
pensions for services performed in connection
apply if the services are performed in the United
Did not become a resident of the United
with a trade or business carried on by Finland or
States by a U.S. resident who either:
States only to perform the services.
its political subdivisions, statutory bodies, or lo
Is a U.S. citizen, or
cal authorities.
Did not become a U.S. resident only to
Pensions paid by Hungary for services per
perform the services.
formed for Hungary are exempt from U.S. in
France
come tax unless the recipient is both a citizen
Pensions paid by Indonesia for services per
and a resident of the United States.
Income, other than a pension, paid by the
formed for Indonesia are exempt from U.S. tax.
French Government or a local authority thereof
Publication 901 (September 2016)
Page 29
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