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HMRC internal manual

International Manual

Double Taxation Agreements: Guernsey: Income from a UK source paid to a resident of Guernsey - UK government pensions

1952 arrangement-effective to 5 April 2010

Paragraph 6 ‘Governmental functions’ makes no provision for relief from UK tax of UK government pensions, and there is therefore no relief in their regard.

Effects of amended arrangement-wef 6 April 2010

The amended arrangement allows for full relief from UK tax for UK government & local authority pensions.

However, no relief is available in respect of the above if the individual has “dual resident” status.

If in any doubt or difficulty regarding “dual residence” please submit case to PT International Advisory (DT), Room 240 St John’s House, Merton Road, Liverpool L75 1BB.