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1. Paragraph 1 of Article 17 of the Convention shall be deleted and replaced by the following:
“1. Periodic pension payments arising in a Contracting State and paid to a resident of the other Contracting State who is the beneficial owner thereof shall be taxable only in that other State.”
2. Paragraph 3 of Article 17 of the Convention shall be deleted and replaced by the following:
“3. For the purposes of this Convention, the term “pension” includes any payment under a superannuation, pension or retirement plan, Armed Forces retirement pay, war veterans' pensions and allowances, and any payment under a sickness, accident or disability plan, as well as any payment made under the social security legislation in a Contracting State.”
3. Paragraph 4 of Article 17 of the Convention shall be deleted and replaced by the following:
“4. For the purposes of this Convention, 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, but does not include any payment under a superannuation, pension or retirement plan or any payment under an income-averaging annuity contract.”
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