Artikel 19

1. a) Remuneration, other than a pension, paid by one of the States or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority may be taxed in that State.
b) However, such remuneration shall be taxable only in the other State if the services are rendered in that State and the individual is a resident of that State who: (i) is a national of that State; or
(ii) did not become a resident of that State solely for the purpose of rendering the services.
(i) is a national of that State; or
(ii) did not become a resident of that State solely for the purpose of rendering the services.
2. a) Any pension paid by, or out of funds created by, one of the States or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority may be taxed in that State.
b) However, such pension shall be taxable only in the other State if the individual is a resident of, and a national of, that State and if immediately prior to the cessation of the services to which the pension relates the remuneration therefor was subject to tax in that State whether under paragraph 1 of this Article or otherwise.
c) For the purposes of this paragraph any pension paid out of the Central African Pension Fund and subject to tax under the law of Zimbabwe shall be treated as if it were a pension paid by, or out of funds created by, Zimbabwe.
3. The provisions of Articles 15, 16 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by one of the States or a political subdivision or a local authority thereof.