(1) Subject to the provisions of paragraph (2) of Article 19 of this Convention, pensions and other similar remuneration paid in consideration of past employment to a resident of a Contracting State and any annuity paid to such a resident shall be taxable only in that State.
(2) Notwithstanding the provisions of paragraph (1) of this Article, pensions paid and other similar payments made by the Government of a Contracting State or political subdivision or a local authority thereof under a public scheme which is part of the social security system of that Contracting State shall be taxable only in that Contracting State.
(3) 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.