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HMRC internal manual

International Manual

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

UK government pensions paid to a resident of Ireland

Article 18: ‘Government service’ applies where a pension is paid by a state,a political sub- division or a local authority:

  • for ‘services of a governmental nature’, or
  • where the individual was employed in a publicly-funded educational institution,


  • the pension is paid out of UK public funds, and
  • the recipient is a national of both the UK and Ireland.

Under this Article and from 6 April 1999 onwards, a resident ofIreland who is a dual national (of both the UK and Ireland) or a sole national of Ireland,is entitled to relief from UK tax in respect of a pension paid out of public funds.

But anyone resident in Ireland who is a sole national of the UK, or anational of any other state, remains subject to UK tax on their government pension.

There is a question about nationality on the claim form, and notes on thesubject at INTM353585.

Further information about what is meant by the term “Government pension” can befound at INTM343020.