Pensions, Annuities and Similar Payments
(1) Subject to the provisions of paragraph (2) of Article 19, pensions and similar payments or annuities paid to a resident of a Contracting State from the other Contracting State shall only be taxable in the first-mentioned State.
(2) Notwithstanding the provisions of paragraph (1), payments received by an individual being a resident of a Contracting State from the statutory social insurance of the other Contracting State shall be taxable only in that other State.
(3) Notwithstanding the provisions of paragraph (1), recurrent or non-recurrent payments made by one of the Contracting States or a political subdivision thereof to a person resident in the other Contracting State as a compensation based on the public law of the first-mentioned State shall be taxable only in the first-mentioned State.
(4) 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.
(5) Maintenance payments, including those for children, made by a resident of one Contracting State to a resident of the other Contracting State shall be exempted from tax in that other State. This shall not apply where such maintenance payments are deductible in the first-mentioned State in computing the taxable income of the payer; tax allowances in mitigation of social burdens are not deemed to be deductions for the purposes of this paragraph.