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HMRC internal manual

International Manual

From
HM Revenue & Customs
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DT Agreements: Portugal - Income from a UK source paid to a resident of Portugal

UK government pensions paid to a resident of Portugal

Article 18 of the Convention

No relief is available.

The Convention says that, unless a person is a Portuguese national without also being a UKnational, pensions paid out of public funds of the UK or of the funds of any localauthority in the UK in respect of services rendered in the discharge of functions of agovernmental nature shall be taxable only in the UK.

Where the person is a Portuguese national without also being a UK national the Conventionprovides for the pension to be taxable in Portugal as well as in the UK.

Although the treaty provides for pensions that are paid by the UK Government to a UKnational to be taxable only in the UK, it is still possible that Portugal may wish to takethese amounts into account when calculating the appropriate rate of Portuguese tax that ischargeable on a resident of Portugal.

You should not comment on the way in which an individual will be taxable in Portugal. Thatis a question for the Portuguese authorities to answer.