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Germany - Liechtenstein Tax Treaty (as amended by 2020 protocol) — Orbitax Tax Hub

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.


Old-Age Pensions, Pensions and Maintenance Payments

(1) Reserving Article 18 Paragraphs (2) and (3), retirement pensions and similar payments or pensions that a person resident in one Contracting State receives from the other Contracting State can only be taxed in the former State.

(2) Irrespective of Paragraph (1) of this Article, benefits that are paid on the basis of laws governing social security benefits in a Contracting State can only be taxed in this State.

(3) Recurring and one-time payments that one of the Contracting States or its regional authorities pays to a person resident in the other Contracting State as fees for damages from political persecution or for an injustice or due to acts during war (including reparations payments) or by the military or civil service authorities or a crime, a vaccination or similar event, can, at variance with Paragraph (1) of this Article, only be taxed in the former State.

(4) The term "pension" means a certain amount that is payable regularly at fixed intervals for the recipient's lifetime or during a specified or specifiable timeframe on the basis of an obligation that provides for these payments as consideration for a commensurate service rendered in money or monetary value.

(5) Maintenance payments including those paid for children, that a person resident in one Contracting State to a person resident in another Contracting State are tax exempt in the other State. To the extent that the maintenance payments are subject to deduction when calculating the taxable income of the party obligated to pay in the former State, they can only be taxed in the other State. Tax exempt amounts intended to reduce social burdens are not considered deductions in the sense of this provision.