„Normally, a double taxation treaty for a pension paid to a non-resident person would generally tax the retirement benefit in the country of residence at retirement,” said Munro O`Dwyer, a partner at PwC. „For ARFs, this will not be the case, according to the details.” From the point of view of national tax legislation, alongside international tax legislation, it should be noted that the provisions agreed in bilateral tax treaties, in the event of a conflict, take precedence over the provisions of national law. The Convention for the avoidance of double taxation takes precedence over national law where a non-resident taxable person satisfies the application of the Convention. In that case, the State of residence shall be exclusively responsible for the taxation of the resident`s income, including income received in the State in whose territory the taxable person operates as a non-resident. . . .