10 February 2022 External T.I. 2019-0819651E5 F - Pension from China -- summary under Article 19

A Canadian resident who had retired from the civil service of the State of China received a pension that was not taxable under the domestic tax law of China. After finding that the pension was taxable as superannuation or pension benefits under s. 56(1)(a)(i), CRA found that the pension was not exempted from Canadian income tax under the Canada-China Treaty given that the exemption under Art. 18 was stated to exclude pensions.