- 1
- Subject to the provisions of Article 18, pensions and other similar remuneration, as well as annuities, paid to a resident of a Contracting State shall be taxable only in that State.
- 2
- Notwithstanding the provisions of paragraph 1:
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- a)pensions and other similar retirement remuneration, as well as annuities, arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in the first-mentioned State.A pension or other similar retirement remuneration or an annuity shall be deemed to arise in a Contracting State insofar as the contributions or payments associated with that pension or other similar retirement remuneration or annuity, or the entitlement to such pension or similar retirement remuneration or annuity qualified for relief from tax in that State.
- b)Pensions and other payments made under the social security legislation of a Contracting State to a resident of the other Contracting State may be taxed in the first-mentioned State.
- 3
- The provisions of this Article shall also apply in case a lump sum payment is made in lieu of a pension, other similar retirement remuneration or an annuity.
- 4
- For the purposes of this Article the term “annuity” means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money’s worth.
