ARTICLE 17
Pensions, Annuities and Similar Payments
(1) Subject to the provisions of paragraph (2) of Article 18, pensions, annuities and other similar payments 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), pensions paid and other payments made under a public scheme which is part of the social security system of a Contracting State, a Land, a political subdivision or a local authority thereof shall be taxable only in that State.
(3) 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.