DT8009 - DT: Germany, Federal Republic: double taxation agreement, Article 10: Pensions and purchased annuities


(1) Any pension (other than a pension of the kind referred to in paragraph (2) of Article 9) and any annuity, derived from sources within the Federal Republic by an individual who is a resident of the United Kingdom and subject to United Kingdom tax in respect thereof, shall be subjected to tax only in the United Kingdom.

(2) Any pension (other than a pension of the kind referred to in paragraph (1) of Article 9) and any annuity, derived from sources within the United Kingdom by an individual who is a resident of the Federal Republic and subject to Federal Republic tax in respect thereof, shall be subjected to tax only in the Federal Republic.

(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.