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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.

ARTICLE 18

Pensions and Annuities

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

(2) However, the provisions of paragraph (1), pensions, annuities and other similar payments made by the Government of a Contracting State, political subdivision or any other local authority under a public scheme which is part of a social welfare system of the State, shall be taxable only in that State.

(3) The term "annuity" means a sum of money paid periodically during the life time or for a certain period of time under an obligation to make payments against adequate benefit and substantial economic benefit.