Pensions taxation: resident-state taxation generally applies, with social security and taxed-source pension exceptions under treaty rules. Pensions and similar remuneration for past employment are generally taxable only in the recipient's State of residence, except that payments under a Contracting State's social security legislation are taxable only in that State. Pensions arising in one Contracting State and paid to a resident of the other are taxable only in the source State if they derive from contributions to a pension scheme by or for the recipient and those contributions, provisions or pensions have been taxed in the source State under its ordinary rules.
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: resident-state taxation generally applies, with social security and taxed-source pension exceptions under treaty rules.
Pensions and similar remuneration for past employment are generally taxable only in the recipient's State of residence, except that payments under a Contracting State's social security legislation are taxable only in that State. Pensions arising in one Contracting State and paid to a resident of the other are taxable only in the source State if they derive from contributions to a pension scheme by or for the recipient and those contributions, provisions or pensions have been taxed in the source State under its ordinary rules.
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