ARTICLE 18
Pensions
(1) Subject to the provisions of paragraph 2 of Article 19, pensions, other similar remuneration in consideration of past employment and annuities paid to a resident of a Contracting State shall be taxable only in that State.
(2) 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.