Pensions and annuities taxable only in the beneficiary's resident state under DTAA, with annuity defined by periodic consideration. Pensions (excluding those in Article 19) and annuities paid to a resident of a Contracting State are taxable only in that resident State; an annuity is a stated sum payable periodically during life or a specified period, made under an obligation in return for adequate and full consideration in money or money's worth.