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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

(1) Subject to the provisions of paragraph (2) 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 that State.

(2) For the purposes of this Article:

  • (a) the term "pensions and other similar remuneration" means regular payments made after retirement in consideration of past service or employment or as compensation for injury or accidents caused to laborers during their service period;
  • (b) the term "life annuities" means a fixed amount paid periodically to an individual for a fixed period 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.