ARTICLE 20
Private Pensions, Annuities, Alimony and Child Support
1. Any pension, other than a pension referred to in Article
19ARenumeration and Pensions in Respect of Government Service)
or any annuity derived by a resident of a Contracting state from
sources within the other Contracting state may be taxed only in
the first-mentioned Contracting state.
2. Notwithstanding paragraph 1, and subject to the
provisions of Article 19 (Remuneration and Pensions in Respect of
Government Service), social security benefits and other public
pensions paid by a Contracting state to a resident of the other
Contracting state or a citizen of the United States shall be
taxable only in the first-mentioned state.
3. The term "pension" means a periodic payment made in
consideration of past services or by way of compensation for
injuries received in the course of performance of services.
4. The term "annuity" means stated sums payable periodically
at stated times during life or during a specified or
ascertainable number of years, under an obligation to make the
payments in return for adequate and full consideration in money
or money’s worth (but not for services rendered).
5. Alimony paid to a resident of a Contracting state shall
be taxable only in that state. The term "alimony” as used in
this paragraph means periodic payments made pursuant to a written
separation agreement or a decree of divorce, separate
maintenance, or compulsory support, which payments are taxable to
the recipient under the laws of the state of which he is a
resident.
6. Periodic payments for the support of a minor child made
pursuant to a written separation agreement or a decree of
divorce, separate maintenance or compulsory support, paid by a
resident of a Contracting state to a resident of the other
Contracting state, shall be taxable only in the first-mentioned
State.