Taxation of pensions: resident state primary; source state may also tax where payer is resident or PE bears payments. Article 18 allocates taxing rights over pensions and similar remuneration: Alternative A confines taxation of pensions paid to a resident to that resident State and treats payments under a public social security scheme as taxable only in the State operating the scheme. Alternative B allows the resident State to tax pensions but permits the other State to tax them if the payer is resident there or if a permanent establishment or fixed base in that other State bore the pension obligation; public social security payments remain taxable only in the operating State.
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.
Taxation of pensions: resident state primary; source state may also tax where payer is resident or PE bears payments.
Article 18 allocates taxing rights over pensions and similar remuneration: Alternative A confines taxation of pensions paid to a resident to that resident State and treats payments under a public social security scheme as taxable only in the State operating the scheme. Alternative B allows the resident State to tax pensions but permits the other State to tax them if the payer is resident there or if a permanent establishment or fixed base in that other State bore the pension obligation; public social security payments remain taxable only in the operating State.
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