Pensions taxation: residence-based rule with source taxation permitted for social security, public scheme benefits, and annuities. Pensions and similar remuneration for past employment paid to a resident are primarily taxable only in the State of residence, subject to Article 19. Notwithstanding that rule, pensions and benefits awarded under social security legislation or public social welfare schemes, whether periodic or lump sum, and annuities arising in a State may be taxed in the State where they arise. 'Annuity' means a stated sum payable periodically during life or a specified period in return for adequate and full consideration in money or money's worth, other than services.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Pensions taxation: residence-based rule with source taxation permitted for social security, public scheme benefits, and annuities.
Pensions and similar remuneration for past employment paid to a resident are primarily taxable only in the State of residence, subject to Article 19. Notwithstanding that rule, pensions and benefits awarded under social security legislation or public social welfare schemes, whether periodic or lump sum, and annuities arising in a State may be taxed in the State where they arise. "Annuity" means a stated sum payable periodically during life or a specified period in return for adequate and full consideration in money or money's worth, other than services.
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