Taxation of pensions: resident state generally has exclusive taxing right, with UN alternatives allowing source-state claims. Pensions for past employment are generally taxable only in the resident State, granting a resident-state taxing right. The UN Model provides Alternative A, under which public social security scheme payments are taxable only in the paying State, and Alternative B, which permits source-state taxation where the payer is a resident or where a permanent establishment or fixed base in the source State incurred and bears the obligation to pay.
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 generally has exclusive taxing right, with UN alternatives allowing source-state claims.
Pensions for past employment are generally taxable only in the resident State, granting a resident-state taxing right. The UN Model provides Alternative A, under which public social security scheme payments are taxable only in the paying State, and Alternative B, which permits source-state taxation where the payer is a resident or where a permanent establishment or fixed base in the source State incurred and bears the obligation to pay.
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