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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.

ARTICLE 17

Pensions and Annuities

(1) Subject to the provisions of paragraph (2) of Article 18, pensions and other similar remuneration and annuities paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that Contracting State. However such pensions and other similar remuneration and annuities may also be taxed in the other contracting State if they arise in that State.

(2) Notwithstanding the provisions of paragraph (1), pensions paid and other payments made under public schemes, which are part of the social security system of a Contracting State or a local authority thereof, shall be taxable only in that Contracting State.

(3) When 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 “annuities” means a stated sum payable to an individual periodically at stated times during life, or during a specified or ascertainable period of them, under an obligation to make the payments in return for adequate and full consideration in money or money’s worth.