Article 18 Pensions, annuities and social security payments

Pensions and other similar remuneration, as well as annuities, including lump-sum payments made in lieu of a pension or another similar remuneration or an annuity, arising in a Contracting State and paid to a resident of the other Contracting State, and payments under the provisions of the social security legislation of the first-mentioned State and paid to a resident of the other Contracting State, may be taxed in the first-mentioned State. However, if such payments are periodic in nature (except lump-sum payments made in lieu of a pension or another similar remuneration or an annuity), the tax so charged shall not exceed 15 per cent of the gross amount of the payment.

A pension, other similar remuneration or an annuity shall be deemed to arise in a Contracting State insofar as the contributions or payments associated with that pension or other similar remuneration or annuity, or the entitlements received from that pension or other similar remuneration or annuity, qualified for relief from tax in that State.

The term ‘annuity’ means a stated sum payable periodically at stated times during life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money’s worth and to the extent that the entitlement or the contribution associated with the annuity qualified for tax relief in the Contracting State from which the annuity is derived.