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(1) Subject to the provisions of paragraph (2) of Article 19 of this Convention, pensions and other similar remuneration, alimony and annuities as well as pensions and other payments under the Social Security System paid to a resident of a Contracting State 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.
(3) Notwithstanding the provisions of paragraph (1) of this Article, any alimony or other maintenance payment paid by a resident of one of the Contracting States to a resident of the other Contracting State, shall, if it is not allowable as a relief to the payer, be taxable only in the first mentioned State.
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