Client has lived for some years in Australia and is tax-resident there.
Formerly, he was UK resident and built up a substantial UK occupational pension, currently deferred.
The pension, which is in the region of £150,000 per annum, starts next year when he turns 65.
At that level there would normally be a substantial Lifetime Allowance Tax Charge not withstanding that he has applied for and received a Certificate for Fixed Protection from HMRC that fixes his LTA at £1,800,000.
However, it looks like Article 18 of the UK/Australia Double Tax Treaty might protect him from the LTA charge because it provides that pensions are only taxable in the state of residence of the recipient - in this case Australia.
I don't have too much experience of the operation of Double Tax Treaties so I would be very grateful if anyone could confirm that Article 18 of the Australian Treaty would protect the client from a LTA tax charge.