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(1) Subject to the provisions of paragraph (2) of Article 19 of this Convention, 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 the other Contracting State and any annuity paid to such a resident from such a source shall be taxed only in that other State.
(2) The term “annuity” means a stated sum payable to an individual periodically at stated times during his 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.
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