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HMRC internal manual

Double Taxation Relief Manual

DT: Barbados: double taxation agreement, Article 14: Governmental functions

(1) Remuneration, including pensions, paid by a Contracting State to an individual for services rendered to that State in the discharge of governmental functions shall be exempt from tax in the other Contracting State if the individual is not ordinarily resident in that other State or (where the remuneration is not a pension) is ordinarily resident in that other State solely for the purpose of rendering those services.

(2) The provisions of this Article shall not apply to payments in respect of services rendered in connection with any trade or business carried on by either of the Contracting States for purposes of profit.