Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 32
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34for government services is exempt from U.S.
These exemptions do not apply to income or
U.S. income tax. However, the exemption does
tax. However, the exemption does not apply if
pensions for services performed in connection
not apply to payments for services performed in
the services are performed in the United States
with a business carried on by South Africa or its
the United States by a resident of the United
by a U.S. resident who either:
subdivisions or local authorities.
States who either:
Is a U.S. citizen, or
Is a U.S. citizen, or
Did not become a U.S. resident solely for
Did not become a U.S. resident only to
Spain
the purpose of performing the services.
perform the services.
Income, other than a pension, paid by Spain, its
Pensions paid by Switzerland for services
Pensions paid by Russia, its republics, or lo
political subdivisions, or local authorities to an
performed for Switzerland are exempt from U.S.
cal authorities for services performed for Russia
individual for services performed for the paying
income tax unless the recipient is both a resi
are exempt from U.S. tax unless the individual
governmental body is exempt from U.S. income
dent and citizen of the United States.
is both a resident and citizen of the United
tax. However, the exemption does not apply to
States.
payments for services performed in the United
These exemptions do not apply to income or
States by a resident of the United States who
pensions for services performed in connection
either:
These exemptions do not apply to income or
with a business carried on by Switzerland or its
Is a U.S. citizen, or
pensions for services performed in connection
subdivisions or local authorities.
Did not become a U.S. resident only to
with a business.
perform the services.
Thailand
Slovak Republic
Pensions paid by Spain, its political subdivi
Income, other than a pension, paid by Thailand
sions, or local authorities for services performed
Income, including a pension, paid from the pub
or its political subdivisions or local authorities to
for Spain are exempt from U.S. tax unless the
lic funds of the Slovak Republic, its political
an individual for services performed for the pay
individual is both a citizen and resident of the
subdivisions, or local authorities to a Slovak citi
ing governmental body is exempt from U.S. in
United States.
zen for services performed in the discharge of
come tax. However, the exemption does not
governmental functions is exempt from U.S. in
apply to payments for services performed in the
These exemptions do not apply to income or
come tax. This exemption does not apply to in
United States by a resident of the United States
pensions for services performed in connection
come paid for services performed in connection
who either:
with a trade or business carried on by Spain, its
with a business carried on by the Slovak Re
Is a U.S. citizen, or
subdivisions, or local authorities.
public, its political subdivisions, or local authori
Did not become a U.S. resident only to
ties.
perform the services.
Sri Lanka
Slovenia
Pensions paid by Thailand for services per
Income, including a pension, paid from the pub
formed for Thailand are exempt from U.S. in
lic funds of Sri Lanka, its political subdivisions,
Income, other than a pension, paid from public
come tax unless the recipient is both a resident
or local authorities to a citizen or national of Sri
funds of Slovenia, its political subdivisions, or
and citizen of the United States.
Lanka for services performed for Sri Lanka in
local authorities to an individual for services
the discharge of functions of a governmental
performed for the paying governmental body in
These exemptions do not apply to income or
nature is exempt from U.S. income tax. This ex
the discharge of governmental functions is ex
pensions for services performed in connection
emption does not apply to income paid for serv
empt from U.S. income tax. However, the ex
with a business carried on by Thailand or its
ices performed in connection with a business
emption does not apply if the services are per
subdivisions or local authorities.
carried on by Sri Lanka, its political subdivi
formed in the United States by a resident of the
sions, or local authorities.
United States who either:
Trinidad and Tobago
Is a U.S. citizen, or
Sweden
Did not become a U.S. resident only to
Wages, salaries, and similar income and pen
perform the services.
sions, annuities, and similar benefits paid by or
Income, other than a pension, paid by Sweden,
from the public funds of the Government of Tri
its political subdivisions, or local authorities to
Pensions paid from the public funds of Slov
nidad and Tobago to a national of that country
an individual for services performed for the pay
enia, its political subdivisions, or local authori
for services performed for Trinidad and Tobago
ing governmental body is exempt from U.S. in
ties for services performed for Slovenia in the
in the discharge of governmental functions are
come tax. However, the exemption does not
discharge of governmental functions are ex
exempt from U.S. tax.
apply if the services are performed in the United
empt from U.S. income tax unless the recipient
States by a U.S. resident who either:
is both a resident and citizen of the United
Tunisia
Is a U.S. citizen, or
States.
Did not become a U.S. resident solely for
Income, other than a pension, paid by Tunisia,
the purpose of performing the services.
South Africa
its political subdivisions, or local authorities to a
Tunisian citizen for personal services per
Pensions paid by Sweden, its political subdi
Income, other than a pension, paid by South Af
formed in the discharge of governmental func
visions, or local authorities for services per
rica or its political subdivisions or local authori
tions is exempt from U.S. income tax.
formed for Sweden are exempt from U.S. tax
ties to an individual for services performed for
unless the individual is both a resident and citi
Pensions paid by Tunisia, its political subdi
the paying governmental body is exempt from
zen of the United States.
visions, or local authorities for services per
U.S. income tax. However, the exemption does
formed for Tunisia are exempt from U.S. in
not apply to payments for services performed in
These exemptions do not apply to income or
come tax unless the recipient is a U.S. citizen.
the United States by a resident of the United
pensions for services performed in connection
States who either:
with a business carried on by Sweden, its politi
These exemptions do not apply to income or
Is a U.S. citizen, or
cal subdivisions, or local authorities.
pensions for services performed in connection
Did not become a U.S. resident only to
with a trade or business carried on by Tunisia,
perform the services.
Switzerland
its political subdivisions, or local authorities.
Pensions paid by South Africa for services
Income, other than a pension, paid by Switzer
performed for South Africa are exempt from
land or its political subdivisions or local authori
U.S. income tax unless the recipient is both a
ties to an individual for services performed for
resident and citizen of the United States.
the paying governmental body is exempt from
Page 32
Publication 901 (September 2016)
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