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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 (1) of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in the Contracting State in which they arise. This provision shall also apply to life annuities paid to a resident of a Contracting State.

(2) Pensions and life annuities paid, and other periodical or occasional payments made by a Contracting State in respect of insuring personal accidents shall be taxable only in this State.

(3) The term "annuity" as used in this Article means a stated sum (other than salaries and wages) 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.