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.
- BrightPay 1,041 33
- Regular Director bonus 375 10
- SA REFUND; DEFRAUDED BY UNKNOWN PARTY 203 5
- Footballers Testimonials Taxable? 1,019 17
- Clients have been told I'm working from home 830 13
- HMRC Summons for £14k 429 6
- Partnership Tax Return £100 penalty-was a tax return due in this case? 586 14
- BIK for an electric car 139 2
- New Practice - Accounting Software 3,599 90
- Corporation Tax Software 354 10
- How do I save face? 2,213 14
- Goodie bag 2,999 72
- US Pensions and Renunciation of Citizenship 96 1
- How many associated companies 170 2
- Signed accounts for a lender 432 17
- can I approach clients ? 909 11
- Secure document exchange 586 6
- New Agency rules - who's responsible? 166 2
- FreeAgent question 344 8
- Mortgage interest 136 1
- Possible Partnership? 680
- Tax and accounting treatment on long lease granted from freehold 531
- Fuming! 499
- New Fangled Penalties 465
- Purchase of property freehold - capitalisation of costs 329
- Charity dissolution and newly merged charity 271
- Moving away from CCH software 261
- Lenovo – Superfish & Komodia – is your PC vulnerable 251
- Outsource Data Entry 249
- Do I need a US Tax Identification Number to complete W-8BEN-E? 203