Pensions and Annuities
(1) Subject to the provisions of paragraph (2) of Article 20, pensions and other similar remuneration and annuities paid to an individual who is a resident of a Contracting State in consideration of past employment may be taxed in the first-mentioned State.
(2) Notwithstanding the provisions of paragraphs (1), pensions paid and other payments made under a public scheme which is part of the social security system of a Contracting State, or a political subdivision or a local authority thereof shall be taxable only in that State.
(3) As used in this Article:
- (a) the terms “pensions and other similar remuneration” mean periodic payments made after retirement in consideration of past employment or by way of compensations for injuries received in connection with past employment;
- (b) the term “annuity” means a stated sum payable to an individual 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.