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HMRC internal manual

Double Taxation Relief Manual

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Double Taxation Relief Manual: Guidance by country: Ireland: Government remuneration and pensions

The following chart sets out the treatment of remuneration and pensions paid by or out of funds created by the United Kingdom or Ireland or a local authority in respect of services rendered to one or other of the two countries in the discharge of functions of a governmental nature (Article 18). It illustrates the differing treatment depending on the nationality (see DT9876) of the individual receiving the remuneration or pension. The chart does not apply to remuneration or pensions paid in respect of services rendered in connection with any trade or business; the provisions of Article 15 (Remuneration) or Article 17 (Pensions) apply in these circumstances.

1999-00 and later years

INCOME PAID FROM THE UNITED KINGDOM PAID TO A RESIDENT OF IRELAND WHO IS NOT AN IRISH NATIONAL PAID TO A RESIDENT OF IRELAND WHO IS AN IRISH NATIONAL    
         
  Chargeable in the United Kingdom Chargeable in Ireland Chargeable in the United Kingdom Chargeable in Ireland
Government remuneration – services rendered in Ireland On the full amount Not chargeable Not chargeable On the full amount
Government remuneration – services rendered elsewhere On the full amount Not chargeable On the full amount Not chargeable
Government pension On the full amount Not chargeable Not chargeable On the full amount
INCOME PAID FROM IRELAND PAID TO A RESIDENT OF UNITED KINGDOM WHO IS NOT A UNITED KINGDOM NATIONAL PAID TO A RESIDENT OF UNITED KINGDOM WHO IS AN IRISH UNITED KINGDOM NATIONAL    
         
  Chargeable in the United Kingdom Chargeable in Ireland Chargeable in the United Kingdom Chargeable in Ireland
Government remuneration – services rendered in United Kingdom Not chargeable On the full amount On the full amount Not chargeable
Government remuneration – services rendered elsewhere Not chargeable On the full amount Not chargeable On the full amount
Government pension Not chargeable On the full amount On the full amount Not chargeable