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HMRC internal manual

International Manual

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

State Pension and Incapacity Benefit

State Pension and Incapacity Benefit are not taxable in South Africa and no relief fromUK tax is available.

This is because

  • for income paid from 6 April 2003, NIRP and Incapacity Benefit do not fall within the provisions of either the pensions article or the ‘other income’ articles of the 2002 Convention.
  • for income paid before 6 April 2003, they do not meet the ‘subject to tax’ condition in the 1969 Convention