The application of the doctrine of sovereign immunity to the exercise of government functions is extended into the area of remuneration paid to government officials. Treaties addressing these issues usually distinguish between two categories of government employees. Members of diplomatic missions and consular posts represent states and fulfil traditional roles in international relations and law, on the one hand, and state employees more generally, on the other hand.


The treatment of diplomats, as far as tax treaties are concerned, is normally found in the OECD Model, art. 27. An example of this is found in art. 28 of the Spain-UK double tax treaty (1975), which reads as follows:

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