- 1
- Subject to the provisions of paragraph 2 of this Article and paragraph 1 of Article 20, pensions and other similar remuneration paid in consideration of past employment to a resident of one of the States and any annuity paid to such a resident, shall be taxable only in that State.
- 2
- However, such income may also be taxed in the other State in so far as it is charged as such against profits derived in that other State by an enterprise of that other State or by an enterprise having a permanent establishment therein.
- 3
- Pensions paid out under the provisions of a public social security system of one of the States to a resident of the other State may be taxed in the first-mentioned State.
- 4
- 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.
