- 1
- Subject to the provisions of paragraph 2 of Article 17, pensions and other similar remuneration, as well as annuities, derived by a resident of a Contracting State shall be taxable only in that State. Any pension and other payment under the provisions of a social security system of a Contracting State (social security pension) to a resident of the other Contracting State shall be taxable only in that other State.
- 2
- Notwithstanding the provisions of paragraph 1, pensions or other similar remuneration, as well as annuities or social security pensions, arising in a Contracting State may also be taxed in that State, in accordance with the laws of that State, if the aggregate gross amount of the pensions and other similar remuneration, annuities and social security pensions, including pensions and other similar remuneration referred to in paragraph 2 of Article 17, exceeds in the fiscal year concerned the sum of 15,000 Euro.
- 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 the payments in return for adequate and full consideration in money or money’s worth.
- 4
- A pension or other similar remuneration or annuity shall be deemed to arise in a Contracting State insofar as the contributions or payments associated with that pension or similar remuneration or annuity, or the entitlements received from them, qualified for tax relief in that State. The transfer of a pension, other similar remuneration or annuity 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.
- 5
- The provisions of this Article shall also apply in case a lump sum payment is made in lieu of a pension or other similar remuneration or annuity.
