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..... er, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other State and the recipient is a resident of that other State who : (a) is a citizen of that State; or (b) did not become a resident of that State solely for the purpose of performing the services. 2. Any pension paid by, or out of funds created by, one of the Contracting States .....

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