Pension taxation: resident-state generally has exclusive taxing right, but social security benefits and annuities may be taxed in source state. Pensions and similar employment-related remuneration paid to a resident are taxable only in the State of residence, subject to Convention limits; however, pensions and benefits under a Contracting State's social security or public social welfare schemes, and annuities arising in a Contracting State, may be taxed in the State where they arise. Annuity is defined as a stated periodic sum payable during life or for a specified period in return for adequate consideration in money or money's worth (other than services).
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.
Pension taxation: resident-state generally has exclusive taxing right, but social security benefits and annuities may be taxed in source state.
Pensions and similar employment-related remuneration paid to a resident are taxable only in the State of residence, subject to Convention limits; however, pensions and benefits under a Contracting State's social security or public social welfare schemes, and annuities arising in a Contracting State, may be taxed in the State where they arise. Annuity is defined as a stated periodic sum payable during life or for a specified period in return for adequate consideration in money or money's worth (other than services).
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