Pensions and annuities: taxation generally confined to the recipient's state of residence under the treaty. Article 20 allocates taxing rights so that any pension or annuity paid to a resident of a Contracting State is taxable only in that State, subject to the exception in Article 19(2). The Article defines 'pension' as periodic payments for past employment, compensation for employment injuries, and social security payments of either Contracting State, and defines 'annuity' as a stated periodic sum payable during life or a specified period in return for adequate and full consideration in money or money's worth.
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.
Pensions and annuities: taxation generally confined to the recipient's state of residence under the treaty.
Article 20 allocates taxing rights so that any pension or annuity paid to a resident of a Contracting State is taxable only in that State, subject to the exception in Article 19(2). The Article defines "pension" as periodic payments for past employment, compensation for employment injuries, and social security payments of either Contracting State, and defines "annuity" as a stated periodic sum payable during life or a specified period in return for adequate and full consideration in money or money's worth.
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