- 1
- Subject to the provisions of paragraph 2 of Article 18 pensions and other similar remuneration, including annuities and any lump-sum payments, derived from a Contracting State and paid to a resident of the other Contracting State, may be taxed in the first-mentioned State.
- 2
- Pensions paid and other payments made under the provisions of a social security system of a Contracting State to a resident of the other Contracting State, may be taxed in the first-mentioned State.
- 3
- Whether and to what extent a pension or similar remuneration falls under this Article or under Article 18, is determined by the nature of the past employment or profession, as private or governmental, during which the entitlement to that part of the pension or similar remuneration was built up.
