Article 19 is subject to the saving clause of paragraph 4 of Article 1 (General Scope).

Thus, for example, a U.S. citizen who is resident of Venezuela and receives a pension payment from the United States may be subject to U.S. tax on the payment, notwithstanding the rules in Article 19 that give Venezuela the exclusive taxing right. Because paragraph 2 does not restrict either State’s right to tax social security payments, the saving clause is irrelevant.