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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 (1) and (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 according to its domestic laws.

(2) Notwithstanding the provisions of paragraph (1) of this Article, pensions and other similar remuneration paid under the social security laws of a Contracting State according its domestic laws to a resident of the other Contracting State shall be taxable in the first- mentioned Contracting State.

(3) The provisions of paragraphs (1) and (2) of this Article, shall not affect the application of law in a Contracting State regarding exemption of pensions from taxes.