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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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DT: Swaziland: double taxation agreement, Article 16: Pensions

(1) Subject to the provisions of paragraph (1) of Article 17, pensions and other similar remuneration paid in consideration of past employment to a resident of a Contracting State and any annuity paid to such a resident shall be taxable only in that State.

(2) 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.