Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 31
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34Netherlands
U.S. income tax unless the recipient is both a
does not apply to payments for services per
resident and citizen of the United States.
formed in connection with any trade or business
Income, other than a pension, paid by the Neth
carried on for profit.
erlands, its political subdivisions, or local au
These exemptions do not apply to income or
thorities to an individual for services performed
pensions for services performed in connection
Philippines
for the paying governmental body is exempt
with a trade or business carried on by Luxem
from U.S. income tax. However, the exemption
bourg, its political subdivisions, or local authori
Wages, salaries, and similar income, including
does not apply if the services are rendered in
ties.
pensions, annuities, and similar benefits, paid
the United States and the individual is a U.S.
from public funds of the Republic of the Philip
resident who either:
Malta
pines to a citizen of the Philippines (or to a citi
Is a U.S. national, or
zen of another country other than the United
Did not become a U.S. resident solely for
States who comes to the United States specifi
Income, other than a pension, paid by Malta, its
the purpose of performing the services.
cally to work for the Government of the Philip
political subdivisions, or local authorities to an
pines) for labor or personal services performed
individual for services performed for the paying
Pensions paid by the Netherlands for serv
as an employee of the national Government of
governmental body is exempt from U.S. income
ices performed for the Netherlands are exempt
the Philippines or any of its agencies in the dis
tax. However, the exemption does not apply if
from U.S. income tax unless the individual is
charge of governmental functions are exempt
the services are performed in the United States
both a resident and national of the United
from U.S. income tax.
by a U.S. resident who either:
States.
Is a U.S. national, or
Did not become a resident of the United
Poland
States solely for purposes of performing
These exemptions do not apply to income or
the services.
pensions for services performed in connection
Wages, salaries, and similar income, including
with a business carried on by the Netherlands,
pensions, annuities, and similar benefits, paid
Pensions paid by Malta, its political subdivi
its political subdivisions, or local authorities.
from public funds of Poland to a citizen of Po
sions, or local authorities for services performed
land (other than a U.S. citizen or one admitted
for the paying governmental body are exempt
to the United States for permanent residence)
New Zealand
from U.S. income tax unless the individual is
for labor or personal services performed as an
both a resident and national of the United
employee of the national Government of Poland
Income (other than pensions) paid by the Gov
States.
in the discharge of governmental functions are
ernment of New Zealand, its political subdivi
exempt from U.S. income tax.
sions, or local authorities for services performed
These exemptions do not apply to income or
in the discharge of governmental functions is
pensions for services performed in connection
Portugal
exempt from U.S. income tax. However, the in
with a business carried on by Malta, its political
come is not exempt if the services are per
subdivisions, or local authorities.
formed in the United States by a U.S. citizen
Income, other than a pension, paid by Portugal,
resident in the United States or by a resident of
its political or administrative subdivisions, or lo
Mexico
the United States who did not become a resi
cal authorities to an individual for services per
dent only to perform the services.
formed for the paying governmental body is ex
Income, other than a pension, paid by Mexico,
empt from U.S. income tax. However, the
its political subdivisions, or local authorities to
exemption does not apply to payments for serv
Pensions paid by New Zealand in consider
an individual for services performed for the pay
ices performed in the United States by a U.S.
ation for past governmental services are ex
ing governmental body is exempt from U.S. in
resident who either:
empt from U.S. income tax unless paid to U.S.
come tax. However, the exemption does not
Is a U.S. national, or
citizens resident in the United States.
apply if the services are performed in the United
Did not become a U.S. resident only to
States by a U.S. resident who either:
perform the services.
These exemptions do not apply to payments
Is a U.S. national, or
for services performed in connection with a
Did not become a resident of the United
Pensions paid by Portugal for services per
business carried on by New Zealand, its politi
States solely for purposes of performing
formed for Portugal are exempt from U.S. in
cal subdivisions, or local authorities.
the services.
come tax unless the recipient is a resident and
national of the United States.
Norway
Pensions paid by Mexico, its political subdi
visions, or local authorities for services per
These exemptions do not apply to income or
Wages, salaries, and similar income, including
formed for the paying governmental body are
pensions for services performed in connection
pensions and similar benefits paid by or from
exempt from U.S. income tax unless the individ
with a business carried on by Portugal or its po
public funds of Norway or its political subdivi
ual is both a resident and national of the United
litical or administrative subdivisions, or local au
sions or local authorities to a citizen of Norway
States.
thorities.
for labor or personal services performed for
Norway or any of its political subdivisions or lo
These exemptions do not apply to income or
Romania
cal authorities in the discharge of governmental
pensions connected with commercial or indus
functions are exempt from U.S. income tax.
trial activities carried on by Mexico, its political
Wages, salaries, and similar income, including
subdivisions, or local authorities.
pensions, annuities, and similar benefits, paid
Pakistan
from public funds of Romania to a citizen of Ro
Morocco
mania (other than a U.S. citizen or one admitted
Income, including pensions and annuities, paid
to the United States for permanent residence)
to certain individuals by or on behalf of the Gov
Wages, salaries, and similar income, including
for labor or personal services performed as an
ernment of Pakistan or the Government of a
pensions and similar benefits, paid from public
employee of the national Government of Roma
Province in Pakistan or one of its local authori
funds of the Kingdom of Morocco to a citizen of
nia in the discharge of governmental functions
ties for services performed in the discharge of
Morocco (other than a U.S. citizen or an individ
are exempt from U.S. income tax.
functions of that Government or local authority
ual admitted to the United States for permanent
is exempt from U.S. income tax. To be exempt
residence) for labor or personal services per
Russia
from tax, these payments must be made to citi
formed for Morocco or for any of its political
zens of Pakistan who do not have immigrant
subdivisions or local authorities in the discharge
status in the United States. This exemption
Income, other than a pension, paid by Russia,
of governmental functions are exempt from U.S.
its republics, or local authorities to an individual
income tax.
Publication 901 (September 2016)
Page 31
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