Chapter INTM153200

Published date09 April 2016
Record NumberINTM153200

The general rule is that pensions paid in consideration of past employment are only taxable in the country of the recipient’s residence. The same applies to annuities. However, some agreements provide that pensions may be taxed in the country where the pension arises - the source country.

An annuity is defined as a stated sum payable to an individual periodically at stated times during life or during a specified period of time under an obligation to make the payments in return for adequate and full consideration in money or money’s worth.

Some agreements include alimony and other similar payments in the pensions Article and these will also then only be taxable...

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