Pension taxation: pensions and similar remuneration are taxable only in the recipient's state of residence, subject to treaty conditions. Pensions and similar remuneration paid to a resident of a Contracting State in consideration of past employment are governed by the treaty and, subject to the cross-reference to paragraph two of Article 20, are taxable only in that State, limiting taxing jurisdiction over employment-related retirement payments to the recipient's state of residence under the double taxation agreement.