Non-government pensions and annuities: taxation generally in residence State, with approved pension fund exception allowing source taxation. Pensions and annuities derived by a resident from sources in the other Contracting State may be taxed only in the resident State, except that payments from a pension fund approved by the Government of the source State to a resident as consideration for past employment may be taxed in the source State; 'pension' means periodic payment for past services or compensation for injuries, and 'annuity' means a stated periodic sum payable for life or a specified period in return for adequate consideration.
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: taxation generally in residence State, with approved pension fund exception allowing source taxation.
Pensions and annuities derived by a resident from sources in the other Contracting State may be taxed only in the resident State, except that payments from a pension fund approved by the Government of the source State to a resident as consideration for past employment may be taxed in the source State; "pension" means periodic payment for past services or compensation for injuries, and "annuity" means a stated periodic sum payable for life or a specified period in return for adequate consideration.
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