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HMRC internal manual

International Manual

DT Agreements: Germany - Income from a UK source paid to a resident of Germany

State Pension and Incapacity Benefit

A State Pension is regarded as “non-government” and is relievable from UKIT under Article X providing that it is ‘subject to tax’ in Germany.

Incapacity Benefit is relievable from UKIT under the terms of Article XV (Other Income) providing it is ‘subject to tax’ in Germany.

See INTM162090 for an explanation of ‘subject to tax’.