Pensions taxable only in resident state under treaty, limiting cross-border taxation of past-employment remuneration for taxpayers. Pensions and other similar remuneration paid for past employment to a resident of a Contracting State are taxable only in that resident State, thereby preventing the source State from taxing such retirement-related payments; this rule is subject to paragraph 2 of Article 19 which may modify interactions with related social-security or pension provisions.
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Provisions expressly mentioned in the judgment/order text.
Pensions taxable only in resident state under treaty, limiting cross-border taxation of past-employment remuneration for taxpayers.
Pensions and other similar remuneration paid for past employment to a resident of a Contracting State are taxable only in that resident State, thereby preventing the source State from taxing such retirement-related payments; this rule is subject to paragraph 2 of Article 19 which may modify interactions with related social-security or pension provisions.
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