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ARTICLE 19

Pensions

(1) Subject to the provisions of paragraph (2) of Article 20, pensions and other similar remuneration in consideration of past employment, and annuities, arising in a Contracting State and paid to a resident of the other Contracting State, may be taxed in the first-mentioned State.

(2) Notwithstanding the provisions of paragraph (1), pensions and other payments made under a public scheme that is part of the social security system of a Contracting State or a political subdivision or a local government thereof shall be taxable only in that State.

(3) As used in this Article:

  • (a) the term "pensions and other similar remuneration" means periodic payments made after retirement in consideration of past employment or by way of compensation for injuries received in connection with past employment;
  • (b) the term "annuity" means a stated sum payable periodically at stated times during life, or during a specified or ascertainable period of time, under an obligation to make the payments in return for adequate and full consideration in money or money's worth (other than services rendered).