- 1
- Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration in consideration of past employment, whether or not of a periodical nature, and annuities and lump-sum payments in lieu of the right to an annuity, arising in one of the Contracting States and paid to a resident of the other Contracting State may be taxed in the first-mentioned State.
- 2
- Any pension and other payment paid out under the provisions of a social security system of one of the Contracting States to a resident of the other Contracting State may be taxed in the first-mentioned State.
- 3
- 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 payments in return for adequate and full consideration in money or money’s worth.
- 4
- A pension or other similar remuneration or annuity is deemed to be derived from one of the Contracting States if and insofar as the contributions or payments associated with the pension or similar remuneration or annuity, or the entitlements received from it qualified for tax relief in that State. The transfer of a pension from a pension fund or an insurance company in one of the Contracting States to a pension fund or an insurance company in another State shall not restrict in any way the taxing rights of the first-mentioned State under this Article.
