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HMRC internal manual

International Manual

Double Taxation Agreements: Spain: Income from a UK source paid to a resident of Spain - UK pensions and annuities paid to a resident of Spain (Article 18)

Full relief is available in respect of:

  • pensions in consideration of past employment
  • annuities

Article 18(2) defines annuities by reference only to payments ‘in return for adequate and full consideration’, and does not include the usual restriction to such consideration ‘in money or money’s worth’. Please refer to CAR Technical Advice Group any problems which may arise from the omission of these words.

For information about Social Security Payments, including National Insurance Retirement Pensions & Incapacity Benefit see INTM343040.

For information about UK government pensions see INTM343040.