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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.


Pensions and Annuities

(1) Subject to the provision 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) For the purposes of this Article:

  • (a) the term "pensions and other similar remuneration" means periodic payments made after retirement in consideration of past employment or by way of compensation for injuries received in connection with past employment.
  • (b) the term "life annuity" means a fixed amount paid to an individual for a fixed term within his lifetime or for the duration of a definite period of time under an obligation to pay the total amount of these installments in a single payment in cash or in cash equivalent.