Pension taxation limits under the DTAA restrict source-state tax where the recipient is resident elsewhere. Pensions and annuities sourced in one Contracting State and received by a resident of the other may be taxed in the source State, but that tax is limited to the lower of a prescribed cap or the tax charged in the resident State. Pensions paid by or from funds of a Contracting State for services in discharge of governmental functions are taxable only in the paying State. 'Annuity' is defined as periodic stated sums 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.
Pension taxation limits under the DTAA restrict source-state tax where the recipient is resident elsewhere.
Pensions and annuities sourced in one Contracting State and received by a resident of the other may be taxed in the source State, but that tax is limited to the lower of a prescribed cap or the tax charged in the resident State. Pensions paid by or from funds of a Contracting State for services in discharge of governmental functions are taxable only in the paying State. "Annuity" is defined as periodic stated sums payable for life or a specified period in return for adequate consideration.
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