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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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DT Agreements: British Virgin Islands - Income from a UK source paid to a resident of the British Virgin Islands (BVI)

Generally, UK source pensions are taxable in the UK.

However, full relief from UK tax is available under the terms of Article 5(2) of the DTA for pensions in consideration of past employment and annuities that are paid to a resident of BVI.

Full relief from UK tax is only available where the individual receiving the pension:

  • belongs to the Virgin Islands (as defined in the Virgin Islands Constitution Order, SI2010 No. 1678)
  • has a certificate of Virgin Islands residence, provided that the individual has lived outside the UK for at least the preceding 10 years.