Subject to the provisions of paragraph 2 of Article 19:
- (a) pensions arising in a Contracting State and paid to a resident of the other Contracting State;
- (b) any payments, whether periodic or non-periodic, made under the social security legislation of a Contracting State or under any public scheme organized by a Contracting State for social welfare purposes;
may be taxed in both Contracting States. However, any payment referred to in sub-paragraph (b) shall not be taxed in the Contracting State of which the recipient is a resident, if that payment due to its nature is exempt from tax in the other Contracting State from which it originates.