ARTICLE 19

Private Pensions and Annuities

(1) Except as provided in Article 21 (Governmental Functions), pensions and other similar remuneration paid to an individual in consideration of past employment shall be taxable only in the Contracting State of which he is a resident.

(2) Alimony and annuities paid to an individual who is a resident of one of the Contracting States shall be taxable only in that Contracting State.

(3) Child support payments made by an individual who is a resident of one of the Contracting States to an individual who is a resident of the other Contracting State shall be exempt from tax in that other Contracting State.

(4) The term "pensions and other similar remuneration," as used in this Article, means periodic payments other than social security payments covered in Article 20 (Social Security Payments) made

(a) by reason of retirement or death and in consideration for services rendered or (b) by way of compensation for injuries or sickness received in connection with past employment.

(5) The term "annuities," as used in this Article, means a stated sum paid periodically at stated times during life, or during a specified number of years, under an obligation to make the payments in return for adequate and full consideration (other than services rendered).

(6) The term "alimony," as used in this Article, means periodic payments made pursuant to a written separation agreement or a decree of divorce, separate maintenance, or compulsory support which payments are taxable to the recipient under the internal laws of the Contracting State of which he is a resident.

(7) The term "child support payments," as used in this Article, means periodic payments for the support of a minor child made pursuant to written separation agreement or a decree of divorce, separate maintenance, or compulsory support.