Pensions taxation: source state may tax pensions paid to residents of the other contracting state under the treaty. Pensions arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in the State where they arise, allocating a source taxing right to that State for cross border pension payments; treatment by the resident State and relief mechanisms are not addressed here.
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: source state may tax pensions paid to residents of the other contracting state under the treaty.
Pensions arising in one Contracting State and paid to a resident of the other Contracting State may be taxed in the State where they arise, allocating a source taxing right to that State for cross border pension payments; treatment by the resident State and relief mechanisms are not addressed here.
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