Pensions taxation: residency and source rules allocate taxing rights, with social security and contribution based pensions taxed at source. Pensions and similar remuneration for past employment are taxable only in the resident State, except that social security payments are taxable only in the paying State. Pensions arising in one Contracting State and paid to a resident of the other are taxable solely in the source State where they derive from contributions or provisions under a pension scheme and those contributions, provisions or pensions have been taxed in the source State under its ordinary tax rules.
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: residency and source rules allocate taxing rights, with social security and contribution based pensions taxed at source.
Pensions and similar remuneration for past employment are taxable only in the resident State, except that social security payments are taxable only in the paying State. Pensions arising in one Contracting State and paid to a resident of the other are taxable solely in the source State where they derive from contributions or provisions under a pension scheme and those contributions, provisions or pensions have been taxed in the source State under its ordinary tax rules.
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