Einde inhoudsopgave
United Nations Model Double Taxation Convention between Developed and Developing Countries 2011
Article 18 Pensions and social security payments
Geldend
Geldend vanaf 15-03-2011
- Bronpublicatie:
15-03-2011, Internet 2011, www.un.org (uitgifte: 15-03-2011, kamerstukken/regelingnummer: -)
- Inwerkingtreding
15-03-2011
- Bronpublicatie inwerkingtreding:
15-03-2011, Internet 2011, www.un.org (uitgifte: 15-03-2011, kamerstukken/regelingnummer: -)
- Vakgebied(en)
Internationaal belastingrecht / Belastingverdragen
Article 18 (alternative A)
1.
Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State.
2.
Notwithstanding the provisions of paragraph 1, pensions paid and other payments made under a public scheme which is part of the social security system of a Contracting State or a political subdivision or a local authority thereof shall be taxable only in that State.
Article 18 (alternative B)
1.
Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment may be taxed in that State.
2.
However, such pensions and other similar remuneration may also be taxed in the other Contracting State if the payment is made by a resident of that other State or a permanent establishment situated therein.
3.
Notwithstanding the provisions of paragraphs 1 and 2, pensions paid and other payments made under a public scheme which is part of the social security system of a Contracting State or a political subdivision or a local authority thereof shall be taxable only in that State.