Replaced by new DTA, which applies in UK from 1st April 2003 for
CT, 6th April 2003 for IT and 1st January 2004 for PRT. For US
withholding taxes it applies from 1st May 2003 and for other US
taxes from 1st January 2004. See DT19939G and H.
(1) Subject to the provisions of paragraph (2) of Article :
19 (Government service), any pension in consideration of past
employment and any annuity paid to an individual who is a resident
of a Contracting State shall be taxed only in that State.
(2) Alimony paid to an individual who is a resident of one
of the Contracting States by an individual who is a resident of the
other Contracting State shall be exempt from tax in the other
Contracting State.
(3) The term `annuity` means a stated sum payable
periodically at stated times during 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.