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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Norway: pensions other than government service pensions (see DT14509)

Under the previous agreement (SI 1985/1988) pensions other than government pensions paid to United Kingdom residents from sources within Norway were exempt from Norwegian tax. Under the 2013 agreement, however, pensions other than government pensions are taxable in Norway. Lump sum payments derived from a pension scheme established in Norway will be taxable only in Norway.

A grandfathering provision will enable United Kingdom residents to make an irrevocable election for their pension to continue to be taxable only in the United Kingdom under the conditions of the previous agreement if they were in receipt of that pension immediately before the entry into force of the 2013 agreement.