Taxation of foreign government pensions: source and residence may both tax, with double-tax relief available. Article 18(3) permits a Government to tax pensions it pays, using permissive language 'may'; this allows both the payor State and the residence State to tax a government pension, and any resulting double taxation is to be relieved under the Treaty's double-tax relief provision.
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 foreign government pensions: source and residence may both tax, with double-tax relief available.
Article 18(3) permits a Government to tax pensions it pays, using permissive language "may"; this allows both the payor State and the residence State to tax a government pension, and any resulting double taxation is to be relieved under the Treaty's double-tax relief provision.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.