Regarding the receipt by an individual resident in Italy of periodic Canada Pension Plan (“CPP”) and Old Age Security (“OAS”) benefit payments, the Directorate stated:
[S]ection 5 of the Income Tax Conventions Interpretations Act provides a definition of the term “pension” in respect of payments that arise in Canada. Both the CPP and OAS are normally considered pensions for purposes of Canada’s tax treaties.
It then found that the OAS payments were social security payments for purposes of the Canada-Italy Treaty.