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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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DT: Yugoslavia: double taxation agreement, Article 18: Pensions

 

(1) 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 the Contracting State of which the individual is a resident.

(2)

(a) Notwithstanding the provisions of paragraph (1) of this Article a pension paid by a Contracting State or a political subdivision or a local authority thereof out of the budget or special funds to an individual shall be taxable only in that State.

(b) However, such a pension shall be taxable only in the other Contracting State if the recipient is a national of and a resident of that State.

(3) Notwithstanding the provisions of paragraph (2) of this Article a pension derived by an individual for work performed in connection with a business carried on by one of the Contracting States or a political subdivision or a local authority thereof shall be taxable only in the Contracting State of which the individual is a resident.

(4) Pensions derived by individuals in respect of their work in the Joint Economic Representation of Yugoslavia or in the Tourist Federation of Yugoslavia shall be taxable in accordance with the provisions of paragraph (2) of this Article.

(5) 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.