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UNITED STATES MODEL INCOME TAX CONVENTION OF NOVEMBER 15, 2006

Article 17

U.S. Income Tax Treaty — united states model tax treaty documents: model006.pdf · 2026-10-03 edition · updated 2026-10-04 · United States

PENSIONS, SOCIAL SECURITY, ANNUITIES,

ALIMONY, AND CHILD SUPPORT

  1. a) Pensions and other similar remuneration beneficially owned by a resident of a Contracting State shall be taxable only in that State.

b) Notwithstanding subparagraph a), the amount of any such pension or remuneration arising in a Contracting State that, when received, would be exempt from taxation in that State if the beneficial owner were a resident thereof shall be exempt from taxation in the Contracting State of which the beneficial owner is a resident.

  1. Notwithstanding the provisions of paragraph 1, payments made by a Contracting State under 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 first-mentioned State.

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

  3. Alimony paid by a resident of a Contracting State 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.

  4. Periodic payments, not dealt with in paragraph 4, for the support of a 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 be exempt from tax in both Contracting States.

2006 U.S. Model Income Tax Convention

  • 26

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▸Contents — U.S. Income Tax Treaty — united states model tax treaty documents: model006.pdf
U.S. Income Tax Treaty — united states model tax treaty documents: model006.pdf

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