background image
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 Life Annuities

(1) Pensions and life annuities, originating from a Contracting State and paid to a resident of the other Contracting State, shall be taxable only in that other Contracting State irrespective of the residence of the beneficiary.

(2) 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.