Pensions and Annuities
(1) Any pension (other than a pension of the kind referred to in paragraph (3)) or any annuity paid to a resident of a Contracting State may be taxed in that State.
(2) However, such pension or annuity derived by an individual who is a resident of a Contracting State from sources within the other Contracting State may be taxed in that other State, but the tax so charged shall not exceed 5 per cent of the gross amount of the payment.
(3) Any pension paid by, or out of funds created by, a Contracting State, a political subdivision or a local authority thereof, to any individual shall be taxable only in that State.
(4) The term "pension" means a periodic payment made in consideration of services rendered in the past or by way of compensation for injuries received.
(5) The term "annuity" 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.