ARTICLE 22. PRIVATE PENSIONS AND ANNUITIES
U.S. Income Tax Treaty — Technical Explanation 1970 · 2026-10-03 edition · updated 2026-10-04 · United States
The proposed Convention provides that private pensions, private life an nuities. and alimony which are paid to an individual who is a resident of one of the States shall be exempt from tax In the State of source.
The term "life annuities" is defined to mean a stated sum paid periodically at stated times during life, or during a specified number of years, under an obligation to make payments In return for adequate and full consideration in money or money's worth.
The term "pension" is defined as periodic payments made after retirement or death in consideration for services rendered. or by way of compensation for Injuries received in connection with past employment.
The term "alimony" is defined as periodic payments made pursuant to a decree of divorce or of separate maintenance which are taxable to the recipient under the internal laws of the State of which he is a resident. Thus, the term "alimony" would not include a payment which would not be taxable to the recipient under the laws of the State in which he Is a resident even though such payment is made pursuant to a decree of divorce or of separate maintenance.
The effect of this provision is the same as that of the OECD Model Convention.
BELGIUM 405
105
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