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Topic: US Pension taxable in the UK?  (Read 1549 times)

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US Pension taxable in the UK?
« on: July 04, 2018, 01:13:55 PM »
I am considering a move to the UK when my divorce is finalized, but trying to understand all of the tax implications if I do.

I retired about 5 years ago and collect a regular US Gov civil service pension.  All of the contributions were made while a resident of the US, and I have been collecting from the CSRS Defined benefit plan since I retired.  So...

If I do move to the UK, is that pension income taxable in the UK?  Would I have to file a UK tax return/forms even if it isn't taxable?

I did try searching the forum, but couldn't find anything recent that addressed it.


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Re: US Pension taxable in the UK?
« Reply #1 on: July 04, 2018, 03:20:52 PM »
Hi. A government pension would not be taxable in the UK. You might need to do a self-assessment, if you have other income, and report the pension in the advice section (not as foreign income) and state something like:

"Pension received for services to the USA Government is not subject to UK tax, per the provisions of Article 19, Section 2(A), of the United Kingdom-USA  Income Tax Treaty."

If you don't have other income, I believe you don't need to file a self-assessment. If you are going to draw social security (not sure you will if you are Civil Service), you have to report that on a self-assessment and pay UK tax on it. It's not taxable in the USA. 


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Re: US Pension taxable in the UK?
« Reply #2 on: July 04, 2018, 05:41:18 PM »
Hi. A government pension would not be taxable in the UK. You might need to do a self-assessment, if you have other income, and report the pension in the advice section (not as foreign income) and state something like:

"Pension received for services to the USA Government is not subject to UK tax, per the provisions of Article 19, Section 2(A), of the United Kingdom-USA  Income Tax Treaty."

If you don't have other income, I believe you don't need to file a self-assessment. If you are going to draw social security (not sure you will if you are Civil Service), you have to report that on a self-assessment and pay UK tax on it. It's not taxable in the USA. 
This comment it too broad. It depends. We do not know the citizenship of the OP. US government pensions can be UK taxable. In my opinion - incidentally - the white space note is insufficient because it does not state the amount of the government pension that one is electing to be UK tax exempt.


Re: US Pension taxable in the UK?
« Reply #3 on: July 04, 2018, 11:47:53 PM »
This comment it too broad. It depends. We do not know the citizenship of the OP. US government pensions can be UK taxable. In my opinion - incidentally - the white space note is insufficient because it does not state the amount of the government pension that one is electing to be UK tax exempt.

Dual citizen, US by birth, UK by descent.  The retirement will be around $62,500 per year before US Income Tax, and around $47,500 after US Income Tax, if my guesstimates are close.


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Re: US Pension taxable in the UK?
« Reply #4 on: July 05, 2018, 09:14:47 AM »
Reference for you from the Air Force Midenhall retirees site  - Military pension would be the same as Civil Service, as they are both government.

http://www.mildenhall.af.mil/About-Us/Fact-Sheets/Display/Article/270380/retiree-activity-program/

and the treaty

https://www.gov.uk/government/publications/usa-tax-treaties

You'll want to read the treaty carefully. If you're a UK citizen, you're going to want to read 19.2.b.

Good luck!
« Last Edit: July 05, 2018, 09:21:43 AM by Nan D. »


Re: US Pension taxable in the UK?
« Reply #5 on: July 05, 2018, 12:05:11 PM »
Reference for you from the Air Force Midenhall retirees site  - Military pension would be the same as Civil Service, as they are both government.

http://www.mildenhall.af.mil/About-Us/Fact-Sheets/Display/Article/270380/retiree-activity-program/

and the treaty

https://www.gov.uk/government/publications/usa-tax-treaties

You'll want to read the treaty carefully. If you're a UK citizen, you're going to want to read 19.2.b.

Good luck!

thank you for the links.

I must be particularly thick, because I am not sure what 19.2.b is really saying.

but it is tax law, so it's not supposed to be easy to understand, I guess.


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Re: US Pension taxable in the UK?
« Reply #6 on: July 05, 2018, 12:45:00 PM »
I know the feeling, believe me! Translation for a US citizen, below, as I read it [brackets are mine]:

From Article 19

2. Notwithstanding the provisions of paragraphs 1 and 2 of Article 17 (Pensions, Social Security, Annuities, Alimony, and Child Support) of this
Convention:
(a) any pension paid by, or out of funds created by, a Contracting State [USA] or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall, subject to the provisions of sub-paragraph b) of this paragraph, be taxable only in that [USA] State;
(b) such pension, however, shall be taxable only in the other Contracting State [UK} if the individual is a resident of, and a national of, that State. [UK]

So,

A US (only) citizen living in the UK on a US government pension would not have the pension taxed by the UK.
A UK (or dual) citizen living in the UK on a US government pension would have the pension taxed by the UK.


Re: US Pension taxable in the UK?
« Reply #7 on: July 05, 2018, 03:21:03 PM »
I know the feeling, believe me! Translation for a US citizen, below, as I read it [brackets are mine]:

From Article 19

2. Notwithstanding the provisions of paragraphs 1 and 2 of Article 17 (Pensions, Social Security, Annuities, Alimony, and Child Support) of this
Convention:
(a) any pension paid by, or out of funds created by, a Contracting State [USA] or a political subdivision or a local authority thereof to an individual in respect of services rendered to that State or subdivision or authority shall, subject to the provisions of sub-paragraph b) of this paragraph, be taxable only in that [USA] State;
(b) such pension, however, shall be taxable only in the other Contracting State [UK} if the individual is a resident of, and a national of, that State. [UK]

So,

A US (only) citizen living in the UK on a US government pension would not have the pension taxed by the UK.
A UK (or dual) citizen living in the UK on a US government pension would have the pension taxed by the UK.

Thank you for the clarification.  it is kind of what I was afraid of, and may just thwart a move to the UK depending on the tax rates.  I am at 22% in the US, and have a partial exemption because of my .gov service.

Thank you again for the help :)


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Re: US Pension taxable in the UK?
« Reply #8 on: July 05, 2018, 05:48:52 PM »
No probs.

Reminder the the tax runs by tiers.   For $62,500 at about $1.32 per pound is roughly £47,348:

The first £11,850 is exempt.  Then, for Scotland (England is similar, but not idential):

Over £11,850*-£13,850   Starter Rate 19%
Over £13,850-£24,000  Basic Rate 20%
Over £24,000-£43,430  Intermediate Rate 21%
Over £43,430-£150,000  Higher Rate  41%

So, really, all put together, not a whole lot more than your current 22%. But with no special exemptions, sadly.


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