Article 18 - Pensions and social security payments - Brazil

ARTICLE 18 PENSIONS AND SOCIAL SECURITY PAYMENTS 1. Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration, alimony and annuities paid to a resident of a Contracting State may be taxed in that State. 2. However, such pensions and other similar remuneration, alimony and annuities may also be taxed in the other Contracting State if the payment is made by a resident of that other State or a permanent establishment situated therein. 3. Notwithstanding the provisions of paragraphs 1 and 2, pensions paid and other payments made under a public scheme which is part of the social security system of a Contracting State or a political sub-division or a local authority thereof shall be taxable only in that State. 4. As used in this Article : (a) the term 'pensions and other similar remuneration' means periodic payments made in consideration of past employment or by way of compensation for injuries in connection with past employment; (b) the term annuities means stated sums 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.