Artikel 19

1. (a) Remuneration, other than a pension, paid by one of the States or a political subdivision, a local authority or statutory body thereof to an individual in respect of services rendered to that State, subdivision, authority or body may be taxed only 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. Any pension paid by, or out of funds created by, one of the States or a political subdivision, a local authority or statutory body thereof to an individual in respect of services rendered to that State, subdivision, authority or body may be taxed in that State.
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, a local authority or statutory body thereof.
4. The provisions of paragraphs 1 and 2 shall likewise apply in respect of remuneration or pensions paid by, in the case of Malaysia, the Bank Negara Malaysia, the Malaysian Industrial Development Authority, the Tourist Development Corporation and other government-owned institutions performing the functions of a governmental nature, as may be agreed from time to time between the competent authorities of the States.