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.
ARTICLE 18
Pensions
(1) Subject to the provisions of paragraph (2) of Article 19, any pensions and other similar remuneration for past employment or any annuity for past employment arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable only in that other State.
(2) The term "annuity" means a stated sum payable periodically at stated times during the life of the annuitant or during a specified or ascertainable period of time under an obligation to make the payments in respect of past employment.