Taxation of pensions: pensions arising in a Contracting State are taxable only in that State under the DTAA. Article 18 provides that pensions arising in a Contracting State are taxable only in that State and treats pensions as arising there when the payer is that State, a political subdivision, a local authority, or a resident of that State, thereby establishing a payor-based nexus for primary taxing rights.
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 pensions: pensions arising in a Contracting State are taxable only in that State under the DTAA.
Article 18 provides that pensions arising in a Contracting State are taxable only in that State and treats pensions as arising there when the payer is that State, a political subdivision, a local authority, or a resident of that State, thereby establishing a payor-based nexus for primary taxing rights.
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