Pensions, Annuities and Similar Payments
(1) Subject to the provisions of paragraph (2) of Article 18, pensions, other similar remuneration or annuities arising in a Contracting State and paid to a resident of the other Contracting State, shall be taxable only in that other State.
(2) Notwithstanding the provisions of paragraph (1), payments which are made in accordance with the social insurance legislation of a Contracting State shall be taxable only in that State.
(3) Notwithstanding the provisions of paragraph (1), such a pension, similar remuneration or annuity arising in a Contracting State which is attributable in whole or in part to contributions which, for more than 15 years in that State,
- (a) did not form part of the taxable income from employment, or
- (b) were tax deductible, or
- (c) were tax relieved in some other way shall be taxable only in that State.
This paragraph shall not apply if that State does not effectively tax the pension, other similar remuneration or annuity, or if the tax relief was clawed back for any reason, or if the 15 year condition is fulfilled in both Contracting States.
(4) Notwithstanding the provisions of paragraph (1), recurrent or non-recurrent payments made by one of the Contracting States or a political subdivision thereof to a resident of the other Contracting State as compensation for political persecution or for an injury or damage sustained as a result of war (including restitution payments) or of military or civil alternative service or of a crime, a vaccination or a similar event shall be taxable only in the first-mentioned State.
(5) The term "annuities" means certain amounts payable periodically at stated times, for life or for 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.