Foreign pension

My client is UK resident and ordinarily resident but not UK domiciled. He is in receipt of a foreign pension which under the terms of the tax treaty is taxable only in the country of residence i.e. the UK.

Does this mean that it is necessarily taxed on an arising basis in the UK (with a 10% deduction)?

Alternatively can the pension still fall under the remittance basis option of taxation? If he did pay the £30 000 remittance basis charge it would effectively escape tax in the whole world as he is unlikely to remit the pension to the UK.

I have received conflicting advice on this and would be interested to know what readers think.

Query 17 936 – Conflicted Tax Man

Reply from Cello Boy

Conflicted tax man is thinking of ITEPA 2003 ...