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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.


Pensions and Annuities

(1) Pensions and other similar remuneration, other than those pensions referred to in paragraph (2) of the Article 20, paid to a resident of a Contracting State in consideration of past employment shall be taxable only in the other Contracting State.

(2) The term "pensions, annuities and other remuneration of a similar nature" used in this Article means periodical payments made after retirement, in consideration of past employment or in respect of compensation derived in connection with past employment.

(3) Notwithstanding the provisions of paragraph (1) of this Article, any pensions or annuities and other similar remunerations, paid under the framework of public schemes which is a part of the system of social security of a Contracting State, a political subdivision or its local authority shall be taxable only in that State.