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ARTICLE 18

U.S. Income Tax Treaty — estonia tax treaty documents: estonia.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

Pensions, Social Security, Annuities,

Alimony, and Child Support

  1. Subject to the provisions of Article 19 (Government Service), pensions and other similar remuneration derived and beneficially owned by a resident of a Contracting State in consideration of past employment, whether paid periodically or as a single sum, shall be taxable only in that State, but the amount of any such pension or remuneration that would be excluded from taxable income in the other Contracting State if the recipient were a resident thereof shall be exempt from taxation in the first-mentioned State.

  2. Notwithstanding the provisions of paragraph 1, payments made by a Contracting State under the provisions of the social security or similar legislation of that State to a resident of the other Contracting State or to a citizen of the United States shall be taxable only in the firstmentioned State.

  3. Annuities derived and beneficially owned by a resident of a Contracting State shall be taxable only in that State. The term "annuities" as used in this paragraph means a stated sum (other than a pension) paid periodically at stated times during a specified number of years, under an obligation to make the payments in return for adequate and full consideration (other than services rendered).

  4. Alimony paid by a resident of a Contracting State, and deductible therein, to a resident of the other Contracting State shall be taxable only in that other State. The term "alimony" as used in this paragraph 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 laws of the State of which he is a resident.

  5. Periodic payments, not dealt with in paragraph 4, for the support of a minor child made pursuant to a written separation agreement or a decree of divorce, separate maintenance, or compulsory support, paid by a resident of a Contracting State to a resident of the other Contracting State, shall not be taxable in that other State.

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▸Contents — U.S. Income Tax Treaty — estonia tax treaty documents: estonia.pdf

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