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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.



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

(2) Notwithstanding the provisions of paragraph (1), pensions and other similar remuneration or annuities including payments from the statutory social insurance may also be taxed in the Contracting State in which they arise and according to the laws of that State, but these payments amounting to Rs. 10,000 (including pension allowance) per year shall be exempted in that State. If such payments exceed the aforementioned amount, only the exceeding part shall be subject to tax and the tax so charged shall not exceed 10 percent of the gross amount according to the first sentence.

(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.