Article 18 Pensions, annuities and social security payments

Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid in consideration of past employment, any pension or other payment paid out under the provisions of a social security system, annuities as well as any lump-sum payment in lieu of the aforementioned pensions, payments or annuities derived from a Contracting State and paid to a resident of the other Contracting State, shall be taxable only in the first-mentioned State.

A pension or other similar remuneration or annuity is deemed to be derived from a Contracting State if and insofar as the contributions or payments associated with the pension or other similar remuneration, social security pension or payment, annuity or any lump-sum referred to in paragraph 1 qualified for tax relief in that State. The transfer of a pension from a pension fund or an insurance company in a Contracting State to a pension fund or an insurance company in another State will not restrict in any way the taxing rights of the first-mentioned State under this Article.

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.