(1) Subject to the provisions of paragraph (2) of Article 19 of this Agreement:
(a)pensions and other similar remuneration paid in consideration of past employment, and
(b)any annuity paid,
to an individual who is a resident of a territory, and is subject to tax in respect thereof in that territory, shall be taxable only in that territory.
(2) The term “annuity” means a stated sum payable to an individual periodically at stated times during his life or during a specified or ascertainable period of time under an obligation to make the payments in return for adequate and full consideration in money or money’s worth.
(3) Notwithstanding the provisions of paragraph (1) of this Article, a lump-sum payment beneficially owned by a resident of a territory from a pension scheme established in the other territory shall be taxable only in that other territory.