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Article 20 Government Service
Remuneration, including a pension, paid from the public funds of a Contracting State or a political subdivision or local authority thereof to a citizen of that State in respect of services rendered in the discharge of functions of a governmental nature shall be taxable only in that State. However, the provisions of Article 14 (Independent Personal Services), Article 15 (Dependent Personal Services) or Article 18 (Artistes and Sportsmen), as the case may be, shall apply, and the preceding sentence shall not apply, to remuneration paid from the public funds of a Contracting State or a political subdivision or local authority thereof in respect of services rendered in connection with a business carried on by that State, political subdivision, or local authority.
Article 21 Students, Trainees, Teachers, And Researchers
- 1.
-
- a)
-
An individual who is a resident of a Contracting State at the beginning of his visit to the other Contracting State and who is temporarily present in that other Contracting State for the primary purpose of:
- i)
- studying at a university or other accredited educational institution in that other Contracting State, or
- ii)
- securing training required to qualify him to practice a profession or professional specialty, or
- iii)
- studying or doing research as a recipient of a grant, allowance, or award from a governmental, religious, charitable, scientific, literary, or educational organization,
shall be exempt from tax by that other Contracting State with respect to the amounts described in subparagraph (b) of this paragraph for a period not exceeding five years from the date of his arrival in that other Contracting State.
- b)
-
The amounts referred to in subparagraph (a) of this paragraph are:
- i)
- payments from abroad, other than compensation for personal services, for the purpose of his maintenance, education, study, research, or training;
- ii)
- the grant, allowance, or award; and
- iii)
- income from personal services performed in that other Contracting State in an aggregate amount not in excess of 5,000 United States dollars ($5,000) or its equivalent in Slovak crowns for any taxable year.
- 2.
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An individual who is a resident of a Contracting State at the beginning of his visit to the other Contracting State and who is temporarily present in that other Contracting State as an employee of, or under contract with, a resident of the first-mentioned Contracting State, for the primary purpose of:
- a)
- acquiring technical, professional, or business experience from a person other than that resident of the first- mentioned Contracting State, or
- b)
- studying at a university or other accredited educational institution in that other Contracting State,
shall be exempt from tax by that other Contracting State for a period of 12 consecutive months with respect to his income from personal services in an aggregate amount not in excess of 8,000 United States dollars ($8,000) or its equivalent in Slovak crowns.
- 3.
- An individual who is a resident of one of the Contracting States at the time he becomes temporarily present in the other Contracting State and who is temporarily present in the other Contracting State for a period not exceeding 1 year, as a participant in a program sponsored by the Government of that other Contracting State, for the primary purpose of training, research, or study, shall be exempt from tax by that other Contracting State with respect to his income from personal services in respect of such training, research, or study performed in that other Contracting State in an aggregate amount not in excess of 10,000 United States dollars (USD 10,000) or its equivalent in Slovak crowns.
- 4.
- The competent authorities of the Contracting States may agree to change the amounts specified in paragraphs 1(b)(iii), 2(b) and 3 of this Article to reflect significant changes in price levels.
- 5.
- An individual who visits a Contracting State for the primary purpose of teaching or conducting research at a university, college, school or other accredited educational or research institution in the other Contracting State, and who is, or immediately before such visit was, a resident of the other Contracting State shall be exempt from tax in the first-mentioned Contracting State for a period not exceeding two years in respect of remuneration for such teaching or research. The benefits provided in this paragraph shall not be granted to an individual who, during the immediately preceding period enjoyed the benefits of one of the preceding paragraphs of this Article. An individual shall be entitled to the benefits of this paragraph only once.
- 6.
- This article shall not apply to income from research if such research is undertaken not in the public interest but primarily for the private benefit of a specific person or persons.
Article 22 Other Income
- 1.
- Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Convention shall be taxable only in that State.
- 2.
- The provisions of paragraph 1 shall not apply to income, other than income from real property as defined in paragraph 2 of Article 6 (Income from Real Property (Immovable Property)), if the beneficial owner of the income, being a resident of a Contracting State, carries on or has carried on business in the other Contracting State through a permanent establishment situated therein, or performs or has performed in that other State independent personal services from a fixed base situated therein, and the income is attributable to such permanent establishment or fixed base. In such case the provisions of Article 7 (Business Profits) or Article 14 (Independent Personal Services), as the case may be, shall apply.
Article 23 Capital
- 1.
- Capital represented by real property referred to in Article 6 (Income from Real Property) (Immovable Property)), owned by a resident of a Contracting State and situated in the other Contracting State, may be taxed in that other State.
- 2.
- Capital represented by personal (movable) property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State, or by personal property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other State.
- 3.
- Capital represented by ships, aircraft, and containers owned by a resident of a Contracting State and operated in international traffic, and by personal property pertaining to the operation of such ships, aircraft, and containers shall be taxable only in that State.
- 4.
- All other elements of capital of a resident of a Contracting State shall be taxable only in that State.
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