Artikel 17 Verdrag tussen het Koninkrijk der Nederlanden, ten behoeve van Curaçao, en de Republiek Suriname tot het vermijden van dubbele belasting met betrekking tot belastingen naar het inkomen en naar het vermogen en het voorkomen van het ontduiken en ontwijken van belasting

Article 17 Pensions, annuities and social security payments 1 Pensions and other similar remuneration, as well as annuities arising in a Contracting State and paid to a resident of the other Contracting State shall be taxable in the first-mentioned Contracting State. 2 Pensions paid and other payments made under the provisions of the social security legislation of a Contracting State to a resident of the other Contracting State may be taxed in the first-mentioned State. 3 The transfer of a pension, other similar remuneration or annuity from a recognized pension fund or an insurance company in a Contracting State to a recognized pension fund or insurance company in another State shall not restrict in any way the taxing rights of the first-mentioned State under this Article. 4 The term “annuity” means: a) in the case of annuities arising in Curaçao: an annuity as mentioned in the laws of Curaçao, the benefits of which are part of taxable income from employment and dwellings; b) in the case of annuities arising in Suriname: a fixed 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 (other than services rendered), as long as the benefits qualify as taxable income or the contributions qualify as deductions in Suriname. 5 Payments of a non-periodic nature to which paragraph 1 applies shall only be taxed in the Contracting State from which they arise in accordance with the laws of that Contracting State. A pension or other similar remuneration or annuity shall be deemed to arise in a Contracting State insofar as the contributions or payments by the employer, employee or self-employed individual associated with that pension or other similar remuneration or annuity, or the entitlements received from them, qualified for relief from tax in that Contracting State.