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HMRC internal manual

International Manual

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

UK pensions and annuities paid to a resident of Luxembourg

Article 18 provides for full relief for pensions paid from UK sources exceptfor annuities, government pensions, State Pensions and Incapacity Benefit.

Annuities and Incapacity Benefit can be considered under Article 22 ‘Income notexpressly mentioned’, but there is no relief for NIRPs.

See INTM356405 about government pensions.