Is pension income arising in the UK (and paid to a Belgian resident who is not a Belgian national) taxable in the UK or in Belgium and why?
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See Article 18 and 19 of Treaty
Art 18 - pensions paid in respect of past employment are taxable where the recipient is resident unless Art 19 applies. Art 19 relates to government pensions/
See http://www.hmrc.gov.uk/taxtreaties/in-force/belgium-dtc.pdf for wording of treaty.