- 1
- Subject to the provisions of paragraph 1 of Article 19, pensions and other similar remuneration paid in consideration of past employment and annuities paid to a resident of one of the States shall be taxable only in that State.
- 2
- However, where such remuneration is not of a periodical nature and it is paid to a resident of one of the States who is not a national of that State, in consideration of past employment in the other State, it may be taxed in that other State.
- 3
- Notwithstanding the provisions of paragraph 1, any pension whether or not paid in consideration of past employment and paid out under the provisions of a social security system of one of the States to a resident of the other State may be taxed in the first-mentioned State. However such pension shall be taxable only in the other State if the pension is paid to an individual who is a resident of, and a national of that other 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.
