Artikel VIII

Where before the date on which this Amending Protocol to the Convention comes into effect, a resident of one of the States derives a pension or other similar remuneration, or an annuity arising in the other State, or a pension or other payment under the social security legislation of the other State, and who continues after that date to derive such pension, remuneration, annuity or social security payment, the provisions of Article 18 of the Convention before the entry into force of this Amending Protocol shall remain applicable after the date of the entry into force of this Amending Protocol, unless the person receiving the pension, remuneration, annuity or social security payment elects for application of the provisions of Article 18 of the Convention as amended by this Protocol. Such election has to be made to the tax authorities of both States within two years from the date this Amending Protocol comes into effect and is irrevocable.