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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) Subject to the provisions of paragraph 2 of Article 21, pensions and other similar remuneration paid in consideration of past employment to a resident of a Contracting State or any annuity paid to such a resident shall be taxable only in the State from which such income is derived.

(2) 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.