Article 18 and 19 OECD. from a Dutch perspective Bastiaan Starink LL.M. Budapest, July 5th 2007. Agenda. What is the OECD model tax treaty Intro on art. 18 and 19 Article 19: government pension Article 18: private pension Difficulties Dutch tax treaty policy regarding pensions
from a Dutch perspective
Bastiaan Starink LL.M.
Budapest, July 5th 2007
Article 19 OECD:
2a. Any pension paid by, or out of funds created by, a Contracting State or political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall be taxable only in that State.2b. However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that State.3. The provisions of Article (…) 18 shall apply to (…) pensions in respect of services rendered in connection with a business carries on by a Contracting State or a political subdivision or a local authority thereof.
Article 18 OECD:
Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State in consideration of past employment shall be taxable only in that State.