Non-government pensions and annuities: taxable only in recipient's residence; definitions clarify periodic payments and consideration-based annuities. Non-government pensions and annuities derived by a resident of one Contracting State from sources in the other Contracting State may be taxed only in the resident State. 'Pension' means periodic payments for past services or compensation for service-related injuries. 'Annuity' means a stated periodic sum payable during life or a specified period, paid in return for adequate and full consideration in money or money's worth.
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 and annuities: taxable only in recipient's residence; definitions clarify periodic payments and consideration-based annuities.
Non-government pensions and annuities derived by a resident of one Contracting State from sources in the other Contracting State may be taxed only in the resident State. "Pension" means periodic payments for past services or compensation for service-related injuries. "Annuity" means a stated periodic sum payable during life or a specified period, paid in return for adequate and full consideration in money or money's worth.
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