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HMRC internal manual

International Manual

From
HM Revenue & Customs
Updated
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DT Agreements: Cayman Islands: Income from a UK source paid to a resident of the Cayman Islands - UK pensions/annuities paid to a resident of the Cayman Islands

Generally, UK source pensions are taxable in the UK.

However, full relief from UK tax may be available under the terms of Article 8(2) of the DTA for government pensions and Article 7(2) for other pensions in consideration of past employment and annuities that are paid to a resident of the Cayman Islands.

Full relief from UK tax is only available where the individual receiving the pension has been continuously a resident of the Cayman Islands for:

  • 6 years immediately before the commencement of the pension, or
  • 6 years immediately before the commencement of the employment to which the pension relates