Taxation of pensions: retirement income for a resident is taxable only in the resident State under the treaty. Pensions and analogous payments for past employment paid to a resident of a Contracting State are taxable only in that State, subject to paragraph 2 of Article 19, allocating exclusive taxing rights over retirement income to the State of residence under the treaty.
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Provisions expressly mentioned in the judgment/order text.
Taxation of pensions: retirement income for a resident is taxable only in the resident State under the treaty.
Pensions and analogous payments for past employment paid to a resident of a Contracting State are taxable only in that State, subject to paragraph 2 of Article 19, allocating exclusive taxing rights over retirement income to the State of residence under the treaty.
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