Pensions for past employment are taxable only in the recipient's Contracting State under the treaty. Pensions and similar remuneration paid to a resident of a Contracting State for past employment are taxable only in that State, subject to paragraph 2 of Article 19; the treaty assigns exclusive taxing rights over such retirement benefits to the recipient's State of residence to prevent double taxation.
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Provisions expressly mentioned in the judgment/order text.
Pensions for past employment are taxable only in the recipient's Contracting State under the treaty.
Pensions and similar remuneration paid to a resident of a Contracting State for past employment are taxable only in that State, subject to paragraph 2 of Article 19; the treaty assigns exclusive taxing rights over such retirement benefits to the recipient's State of residence to prevent double taxation.
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