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Non-government pensions taxed only in recipient's State under treaty; annuities and alimony treatment tied to deductible status. Article 18 provides that non-government pensions and annuities received by a resident from sources in the other Contracting State are taxable only in the recipient's State. It defines 'pension' as periodic payments for past services or compensation for injuries and 'annuity' as a stated periodic sum payable for life or a specified period in return for adequate consideration. Alimony paid cross-border is exempt in the recipient State to the extent such payments are not deductible in the payer State.
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.
Non-government pensions taxed only in recipient's State under treaty; annuities and alimony treatment tied to deductible status.
Article 18 provides that non-government pensions and annuities received by a resident from sources in the other Contracting State are taxable only in the recipient's State. It defines "pension" as periodic payments for past services or compensation for injuries and "annuity" as a stated periodic sum payable for life or a specified period in return for adequate consideration. Alimony paid cross-border is exempt in the recipient State to the extent such payments are not deductible in the payer State.
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