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Introducing the βIn Favour Ofβ filter in Case Laws.
Try it now in Case Laws β


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<h1>Resident-state exclusively taxes pensions for past employment; source-state cannot tax except as Article 19(2) allows</h1> Pensions and similar payments for past employment paid to a resident of a Contracting State are taxable only in that State, except as limited by paragraph 2 of Article 19. This allocates exclusive taxing rights over such retirement remuneration to the taxpayer's state of residence, ensuring that the source state does not tax those pension payments except where Article 19(2) provides an exception.