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HMRC internal manual

Double Taxation Relief Manual

DT: Zimbabwe: double taxation agreement, Article 19: Pensions


(1) Subject to the provisions of paragraphs (1) and (2) of Article 20, any pension or other similar remuneration paid to a resident of one of the Contracting States from a source in the other Contracting State in consideration of past employment or services in that other Contracting State and any annuity paid to such a resident from such a source shall be taxable only in that other 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.