Notwithstanding the provisions of Article 17, where a person who is a resident of South Africa on the date on which the Convention comes into effect, continues after that date to derive a pension or other similar remuneration or an annuity as meant in paragraph 1 of Article 17, or continues after that date to derive a pension or other payment paid as meant in paragraph 2 of Article 17, that income shall be taxable only in South Africa if the total gross amount of that income paid out in any calendar year does not exceed 10.000 Euro. However, if the total gross amount of that income arising in the Netherlands and paid out in any calendar year exceeds 10.000 Euro, then it may also be taxed in the Netherlands, but only to the extent that the total gross amount exceeds 10.000 Euro. In that case the Netherlands may include in the basis upon which its tax is imposed on that income that part thereof that is taxable only in South Africa and shall exempt that part by allowing a reduction of its tax in conformity with the provisions of paragraph 2 of Article 23.
