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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.


Retirement Plans, Pensions, and Similar Payments

(1) Subject to the provisions of paragraph (2) of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State.

(2) Other than those referred to in paragraph 1, recurring and one-time payments, made by a Contracting State or by one of its political subdivisions to an individual resident in the other Contracting State to compensate a special victim or for other reasons on the basis of legal principals of public support and pensions or which are the result of warring activities or political persecution or military or non-military service (including reparation payments) shall be taxed, in the first-mentioned State.

(3) The term "pension" means a fixed amount paid to an individual for a fixed term within his lifetime or for the duration of a definite period of time under an obligation to pay the total amount of these installments in a single cash payment or in cash equivalent.