Article 19 - Government Service

Article 19 governs the taxation of salaries, wages, and other remuneration (including pensions) paid by a State, political subdivision, or local authority in respect of services rendered to that State.

Salaries (Article 19(1)): Pay for services rendered to the State of India (e.g. Indian government employees on deputation to United Kingdom) is taxable only in India - except where the services are rendered in United Kingdom and the employee is a national of United Kingdom, or became resident of United Kingdom not solely for the purpose of rendering the services. In that case, United Kingdom taxes.

Pensions (Article 19(2)): Government pensions are taxable only in the paying State (India, in the typical case), unless the recipient is a national and resident of the other State.

Commercial activities exception (Article 19(3)): Where services are rendered in connection with a business carried on by the State (a State-owned commercial enterprise - Air India was a frequent example), Articles 15, 16, and 18 apply instead. The State doesn't get the exclusive-taxation advantage for what is essentially commercial employment.

Diplomatic and consular staff: Covered by Article 28 (Members of Diplomatic Missions) in most India treaties - additional protections under the Vienna Convention overlay the DTAA position.

ICAS / autonomous bodies: Whether an Indian autonomous body (e.g. ICAR, ICMR, CSIR laboratories) qualifies as a "political subdivision" depends on the body's legal status and degree of State control. CBDT has issued clarifications for specific bodies; check the latest position for each.