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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.



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.