Lifetime Allowance Tax Charge
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.
- IT advisory questions? 253 7
- signature required 531 22
- Use of home query 60 1
- Pratice Management Software 154 2
- How can I deal with an unethical accountant? 226 6
- Error in audited accounts 62 1
- Vat registration exception 197 3
- CIS software 73 2
- Homing sandwiches 467 11
- CT600 122 3
- Director appointment not valid - any observations? 180 7
- Settlement discount 144 4
- Director Personal Bank Account in company's books 516 9
- How do I undo the work of a Macro in Excel 184 5
- A number of Clearbooks VAT return issues! 173 2
- VAT on hotel payments received in advance 133 2
- Norwegian p45, which UK Tax return does it go into 216 10
- Left UK in 2006 but did not declare rental income since 2009 136 1
- VAT rate charged by surveyor 190 2
- Related Party Transactions 129 2
- Auto enrolment excuses 1,245
- Feedback on accounts production software for IFRS 816
- Add T&Cs to Sales Order in Sage 523
- Digita Hosted Software 339
- Credit where credit's due....... 314
- Buying goods in US and selling them to company in US 238
- Flat rate VAT- other income calculation 197
- TheTax Donut 181
- Corporation Tax return - more than one trade 162
- Double taxation relief - same income, different individual 162