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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 in consideration of past employment to a resident of a Contracting State shall be taxable only in that State, in accordance with its laws.

(2) Notwithstanding the provisions of paragraph (1), pensions and other payments under the public social security legislation of a Contracting State may be taxed in that State.

(3) Nothing contained in paragraphs (1) and (2) shall affect the provisions of the law of a Contracting State concerning the exemption of pensions from tax.