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HMRC internal manual

International Manual

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

UK pensions/annuities paid to a resident of Japan (Article 19)

Full relief is available in respect of:

  • pensions in consideration of past employment
  • annuities

Article 19(2) defines annuities by reference only to payments ‘in return foradequate and full consideration’, and does not include the usual restriction to suchconsideration ‘in money or money’s worth’. Please refer to Double TaxationTechnical Advice any problems which may arise from the omission of these words.

You should consider relief under Article 23: Income not expressly mentioned (INTM355100) in respect of:

  • State Pensions
  • Incapacity Benefit