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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 Life Annuities

(1) Subject to the provisions of paragraph (2) of Article 19 of this Convention, any pension or other similar remuneration paid in consideration of past employment to a resident of a Contracting State and any annuity paid to such a resident, may be taxed only in that State.

(2) Notwithstanding the provisions of the paragraph (1) of this Article, pensions and other similar remuneration paid under social security laws of a Contracting State, shall only be taxed in that State.

(3) Recurring and non-recurring compensatory payments made by a Contracting State, or by one of its political or administrative subdivisions to a resident of the other Contracting State as compensation for political prosecution, injuries or damages caused to such resident as a result of acts of war (including payments for repairs carried out) or suffered as a result of military or civil service or a crime, including vaccinations or similar occurrences, may be taxed only in the first-mentioned Contracting State, irrespective of the provisions of paragraph (1) of this Article.

(4) The term "annuity" 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 instalments in a single payment in cash or in cash equivalent.