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HMRC internal manual

Double Taxation Relief Manual

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HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Guernsey: Pensions

Under paragraph 5A of the Arrangement, (see DT8600 for the date from which the paragraph had effect), pensions paid from a United Kingdom pension scheme to a resident of Guernsey (who is not also a resident of the United Kingdom, see DT8604) are not taxable in the United Kingdom.

This applies also to United Kingdom government service pensions (those paid to former civil servants, former members of the armed forces, etc) unless the individuals are not “ordinarily resident” in Guernsey. In these limited circumstances, under paragraph 6 of the Arrangement, the pensions are exempt from Guernsey tax and the United Kingdom may still tax the government service pension.