Pensions and annuities: taxable only in the resident Contracting State under the treaty; definitions determine coverage. Payments characterised as pensions or annuities received by a resident of one Contracting State from sources in the other Contracting State are taxable only in the resident State. Pension is defined as periodic payment for past services or compensation for injury in service; annuity is a stated periodic sum payable during life or a specified period in return for adequate and full 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 and annuities: taxable only in the resident Contracting State under the treaty; definitions determine coverage.
Payments characterised as pensions or annuities received by a resident of one Contracting State from sources in the other Contracting State are taxable only in the resident State. Pension is defined as periodic payment for past services or compensation for injury in service; annuity is a stated periodic sum payable during life or a specified period in return for adequate and full consideration.
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