Article 17 Pensions and annuities

Subject to the provisions of paragraph 2 of Article 18, pensions and other similar remuneration, including social security payments, beneficially owned by a resident of a Contracting State shall be taxable only in that Contracting State. However, such pensions and other similar remuneration, including social security payments, may also be taxed in the other Contracting State if they arise in that other Contracting State and they are not adequately subject to tax in the first-mentioned Contracting State.

Annuities derived and beneficially owned by an individual who is a resident of a Contracting State shall be taxable only in that Contracting State. However, such annuities may also be taxed in the other Contracting State if they arise in that other Contracting State and they are not adequately subject to tax in the first-mentioned Contracting State. The term ‘annuities’ as used in this Article means a stated sum paid periodically at stated times during the life of the individual, 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.

Lump sums in lieu of the right to receive a pension or other similar remuneration, or to receive an annuity, paid to an individual who is a resident of a Contracting State shall be taxable only in that Contracting State. However, such lump sums may also be taxed in the other Contracting State if they arise in that other Contracting State.