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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, other similar remuneration and annuities arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in the first-mentioned State.

(2) As used in this Article:

  • (a) the term "pensions and other similar remuneration" means periodic payments made in consideration of past employment or by way of compensation for injuries received in connection with past employment;
  • (b) The term "annuities" means a stated sum payable 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.