Pensions and annuities: residence-based taxation applies, with annuity defined by periodic payments in return for adequate consideration. Article 18 provides that pensions (other than those in Article 19) and annuities paid to a resident of a Contracting State are taxable only in that State, ... Summary
Pensions and annuities: residence-based taxation applies, with annuity defined by periodic payments in return for adequate consideration.
Article 18 provides that pensions (other than those in Article 19) and annuities paid to a resident of a Contracting State are taxable only in that State, establishing a rule of residence-based taxation, and defines "annuity" as a stated sum payable periodically during life or a specified period in return for adequate and full consideration in money or money's worth.
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