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of <h1>Dual Tax Approaches for Pension Payments: Article 18 Offers Resident State Taxation or Shared Taxation Mechanisms</h1> The UN Model Double Tax Avoidance Agreement Article 18 provides two alternative approaches for taxation of pensions and social security payments. Alternative A stipulates that pensions from past employment are taxable only in the resident's state. Alternative B allows taxation in both the resident's state and the state of payment, with specific conditions regarding permanent establishment and payment origin. Both alternatives ensure that public social security payments are taxable exclusively in the originating state.
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