As a contractor with a limited company, my limited company is allowed to contribute up to £40k per year to a company pension plan tax free. I believe there is also a provision for a catchup period of three years. I.e., if I made no contributions in the previous two years, in year 3 I would be able to contribute £120k tax free.
In the US / UK tax treaty, Article 18 section 5 b states:
(b) The reliefs available under this paragraph shall not exceed the
reliefs that would be allowed by the United States to its residents for
contributions to, or benefits accrued under, a generally corresponding pension
scheme established in the United States.
Based on this treaty, can I still contribute £40k / year tax free, or would the maximum be lower due to a US cap on contributions?
Thanks.