Taxation of non-government pensions and annuities: taxable only in the resident state; definitions clarify scope and payment nature. Any pension other than government pensions, and any annuity, derived by a resident of one Contracting State from sources within the other Contracting State shall be taxable only in the resident Contracting State. 'Pension' means a periodic payment made in consideration of past services or as compensation for injuries in the course of services. '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.
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.
Taxation of non-government pensions and annuities: taxable only in the resident state; definitions clarify scope and payment nature.
Any pension other than government pensions, and any annuity, derived by a resident of one Contracting State from sources within the other Contracting State shall be taxable only in the resident Contracting State. "Pension" means a periodic payment made in consideration of past services or as compensation for injuries in the course of services. "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.
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