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HMRC internal manual

Double Taxation Relief Manual

Non-residents: UK income: Pensions: General

Pensions, other than Government pensions (see DT1927), paid in consideration of past employment to a resident of a country with which the United Kingdom has a double taxation agreement are normally taxable only in the country of which the pensioner is a resident but there are exceptions to this. For example, the agreement with Sweden gives limited taxing rights to the source country, the agreement with Zimbabwe gives sole taxing rights to the source country if the employment in respect of which the pension is paid was exercised in the source country, and some other agreements enable both countries to tax such pensions or only give exemption in the source country if the pension is subject to tax in the country of which the recipient is a resident.

Claims by residents of agreement countries to exemption from United Kingdom tax on such pensions are made to HMRC. The relevant office (see DT1820) will authorise non-deduction of United Kingdom tax if a claim is accepted.