Pensions taxation confined to the recipient's state under DTAA, making pension payments taxable only in the state of residence. Subject to paragraph 2 of Article 19, pensions and similar remuneration paid to a resident of a Contracting State in consideration of past employment are taxable only in that State, allocating exclusive taxing authority to the State of residence for employment-related pension income.
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Provisions expressly mentioned in the judgment/order text.
Pensions taxation confined to the recipient's state under DTAA, making pension payments taxable only in the state of residence.
Subject to paragraph 2 of Article 19, pensions and similar remuneration paid to a resident of a Contracting State in consideration of past employment are taxable only in that State, allocating exclusive taxing authority to the State of residence for employment-related pension income.
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