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HMRC internal manual

Double Taxation Relief Manual

DT: Tuvalu and Kiribati: double taxation agreement, Article 8: Governmental functions

(1) Remuneration, including pensions, paid by the Government of one of the territoriesto any individual for services rendered to that Government in the discharge ofgovernmental functions shall be exempt from tax in the other territory if the individualis not ordinarily resident in that other territory or (where the remuneration is not apension) is ordinarily resident in that other territory solely for the purpose ofrendering those services.

(2) The provisions of this paragraph shall not apply to payments in respect of servicesrendered in connection with any trade or business carried on by either of the Governmentsfor purposes of profit.