- 1
- Subject to the provisions of paragraph 3 of this Article and of paragraph 2 of Article 19, pensions and other similar remuneration in consideration of past employment, and any annuities, arising in a Contracting State, and paid to a resident of the other Contracting State may be taxed in that other State.
- 2
- However, such pensions and other similar remuneration derived by a resident of a Contracting State, where the employment was exercised in the other Contracting State, and annuities, derived by a resident of a Contracting State, where arising in the other Contracting State, may also be taxed in that other State and according to the laws of that State, but if the payment is of a periodic nature the tax so charged shall not exceed 20 per cent of the gross amount of the payment.
- 3
- Any pension paid and other payment made under the rules of a social security system of a Contracting State to a resident of the other Contracting State shall be taxable only in the first-mentioned State.
- 4
- The term “annuity” as used in this Article 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 (other than services rendered).
