Pensions taxation: residence generally taxable, but payer-state may tax if payment originates there; public social security taxable only in payer-state. Pensions, similar remuneration, alimony and annuities paid to a resident are taxable in the resident Contracting State; the other Contracting State may also tax such payments if the payer is its resident or a permanent establishment therein. Payments under a public social security scheme of a Contracting State or its subdivisions are taxable only in that State. Definitions clarify that pensions are periodic payments for past employment or injury compensation and annuities are stated periodic sums paid for adequate consideration.
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: residence generally taxable, but payer-state may tax if payment originates there; public social security taxable only in payer-state.
Pensions, similar remuneration, alimony and annuities paid to a resident are taxable in the resident Contracting State; the other Contracting State may also tax such payments if the payer is its resident or a permanent establishment therein. Payments under a public social security scheme of a Contracting State or its subdivisions are taxable only in that State. Definitions clarify that pensions are periodic payments for past employment or injury compensation and annuities are stated periodic sums paid for adequate consideration.
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