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Topic: Canadian pension plan  (Read 503 times)

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Canadian pension plan
« on: April 16, 2018, 07:41:00 AM »
Is Canadian Pension Plan taxable in the UK?


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Re: Canadian pension plan
« Reply #1 on: April 16, 2018, 05:15:33 PM »
Cmoh, perhaps you would add a summary of the circumstances that are relevant to your situation. For instance, your residence position, and the type of benefits - income or lump sum. Without this, it would be difficult to give a meaningful response.


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Re: Canadian pension plan
« Reply #2 on: April 16, 2018, 07:06:41 PM »
Years ago I worked in construction in Canada, my employer took all relevant deductions from my pay which included Canadian Pension Plan, much like US Social Security, I found out a couple of years ago from Canada that I could apply for pension, I receive a small amount monthly in US dollars directly into my US Bank, when I do US taxes I am directed to add this amount to my US Social Security, does UK and Canada have different agreements on taxing Canadian Social Security? Does anyone have similar income from Canada and how do they handle it? I do my taxes in UK by Self Assessment as all my income here comes from retirement from the US.


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Re: Canadian pension plan
« Reply #3 on: April 16, 2018, 07:32:55 PM »
If you are UK resident taxable on the arising basis your UK self-assessment return will report worldwide income and gains.


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Re: Canadian pension plan
« Reply #4 on: April 17, 2018, 11:46:46 AM »
As Guya says, a UK resident is generally taxable on the basis of worldwide earnings. Therefore under UK domestic rules, the Canadian pension is taxable in the UK.

There is a double tax treaty the UK and Canada. Article 17 deals with pensions. Article 17(1) says that a Canadian pension paid to a UK resident is not taxable in Canada but it is taxable in the UK. Article 17(3) confirms that this rule applies to Canadian social security pensions. Therefore the double tax treaty does not remove the Canadian pension from UK taxation.

As regards US taxation, there is a double tax treaty between the US and Canada. Article XVIII(5) deals with social security pensions. It provides that Canadian social security pensions are taxable only in Canada. Unlike the UK treaty, there does not seem to be special provisions for non resident US citizens. Therefore it appears that the pension is not subject to US tax. Please bear in mind that this analysis is only based on a swift reading of the treaty and that I am not generally familiar with its implications. Perhaps others can comment further on this.


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Re: Canadian pension plan
« Reply #5 on: April 17, 2018, 03:23:45 PM »
As Guya says, a UK resident is generally taxable on the basis of worldwide earnings. Therefore under UK domestic rules, the Canadian pension is taxable in the UK.

There is a double tax treaty the UK and Canada. Article 17 deals with pensions. Article 17(1) says that a Canadian pension paid to a UK resident is not taxable in Canada but it is taxable in the UK. Article 17(3) confirms that this rule applies to Canadian social security pensions. Therefore the double tax treaty does not remove the Canadian pension from UK taxation.

As regards US taxation, there is a double tax treaty between the US and Canada. Article XVIII(5) deals with social security pensions. It provides that Canadian social security pensions are taxable only in Canada. Unlike the UK treaty, there does not seem to be special provisions for non resident US citizens. Therefore it appears that the pension is not subject to US tax. Please bear in mind that this analysis is only based on a swift reading of the treaty and that I am not generally familiar with its implications. Perhaps others can comment further on this.

Interesting, will us mere mortals ever figure out these tax codes, Turbo Tax Software tells me to add my Canada SS to the US SS amount,  I talked to a rep in Canada and she said I did not have to file in Ca. maybe because my amount was so small, hardly a tank of petrol in the UK, 3 tanks of gas in the US.


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