Non-government pensions: residence-based taxation confines taxability to the recipient's state of residence. Non-government pensions and analogous remuneration paid in consideration of past employment to a resident of a Contracting State are, subject to Article 19, taxable only in the State of residence, allocating primary tax jurisdiction for such private-sector retirement benefits to that State.
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Provisions expressly mentioned in the judgment/order text.
Non-government pensions: residence-based taxation confines taxability to the recipient's state of residence.
Non-government pensions and analogous remuneration paid in consideration of past employment to a resident of a Contracting State are, subject to Article 19, taxable only in the State of residence, allocating primary tax jurisdiction for such private-sector retirement benefits to that State.
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