CRA considers that a public-sector nurse did not provide services “to Switzerland” for purposes of Art. 18(2)(a) of the Canada-Swiss Treaty

Art. 18(2)(a) of the Canada-Swiss Treaty provides that pensions paid out of funding provided by Switzerland or a political subdivision thereof “in respect of services rendered to Switzerland or subdivision…thereof in the discharge of functions of a governmental nature shall be taxable only in Switzerland.” CRA considered that “services rendered to Switzerland" referred to services rendered in the course of functions of a public character, and did not encompass the exercise by a person of duties as a nurse within the Swiss healthcare sector, “which is essentially dedicated to the provision of services for the benefit of the community as a whole” – so that pensions received by a retired Swiss public-sector nurse would not qualify for the exemption.

Neal Armstrong. Summary of 15 May 2017 External T.I. 2016-0645891E5 Tr under Treaties - Art. 18.