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Posted Sat, 24 Aug 2024 12:23:09 GMT by Susan F
I am resident in the UK. I am over 65 years of age. I have a RRSP in Canada that I am transferring to a RRIF. - I believe that once the RRSP is transferred to a RRIF, there will be no tax to pay on the periodic pension payments in Canada as I am a resident of the UK. - How will I be taxed on the periodic pension payments I receive from the Canadian RRIF? - How will I report the receipt of the periodic pension payments to HMRC? - When will I have to report the receipt of the periodic pension payments to HMRC? Will this be when the payments are made into my Canadian bank account? Or will this be when the payments are received by me in the UK? Please can you answer the above questions and provide me with links to the relevant treaties/regulations/guidance. I have been finding it very difficult to obtain clear answers to the above questions. Thank you.
Posted Mon, 09 Sep 2024 11:26:26 GMT by HMRC Admin 21 Response
Hi Susan F,
The guidance at DT4617, advises that 'Where a UK resident makes a lump sum withdrawal from a Registered Retirement Savings Plan (RRSP) or a Registered Retirement Income Funds (RRIF), Canada imposes a 25 per cent withholding tax'. DT4617 - Double Taxation Relief Manual: Guidance by country: Canada: Withdrawals from Canadian RRSPs/RRIFs.  No tax credit relief is allowable, which means that the full lumpsum is taxable in both Canada and the UK.  You can, however, claim a foreign tax credit relief of up to 100% of the foreign tax deducted, against your Uk tax liability. 
Please also have a look at DT4605 DT4605 - Double Taxation Relief Manual: Guidance by country: Canada: Notes which explains why no tax relief is due for tax paid in Canada.
Thank you.
Posted Mon, 09 Sep 2024 19:07:45 GMT by Susan F
Thank you Admin 21 for your response. I'm sorry to say that you have not addressed my questions. I am concerned with periodic pension payments received from an RRIF. Please will you address my questions about periodic pension payments. Thank you.
Posted Mon, 16 Sep 2024 13:44:39 GMT by HMRC Admin 32 Response
Hi,
The link given on the orignal reply refers to all pensions.
DT4605 - Double Taxation Relief Manual: Guidance by country: Canada: Notes
Thank you.
Posted Sun, 13 Oct 2024 00:07:57 GMT by F W
I'm interested in this question and the two links posted here are not helpful. The first is to an archived page which no longer exists, and the second talks about funds accrued before and after 6 April 2017. This makes no sense as the OP (and myself) has surely had RRSPs started earlier than 6 April 2017, and in my case I don't have any visibility of when the assets in the funds were bought. Is it not the case that if I convert my RRSPs to RRIFs in order to get retirement income, that because of the double taxation agreement I should pay tax only once? I understand that Canada will deduct 25% withholding tax, and on my UK tax return I would declare the gross income from the RRIFs and the tax already paid to the CRA. This would then entitle me to tax credits up to 100% if the tax I have already paid. As the RRIF pays out there will obviously be liquidation of assets within the fund, but I will have no knowledge of which ones will be sold and which ones not. It will be at the fund managers discretion surely?
Posted Wed, 23 Oct 2024 12:35:33 GMT by HMRC Admin 19 Response
Hi,
Per the guidance below, where a UK resident makes a lump sum withdrawal from an RRSP or an RRIF, Canada imposes a 25 per cent withholding tax. No tax credit relief is allowable in the United Kingdom in respect of the tax withheld, however, because the Canadian tax is imposed upon the lump sum withdrawal, which does not itself give rise to a tax charge in the United Kingdom, whereas any UK tax charge is on the disposal of assets held within the Plan or Fund to enable the lump sum to be withdrawn, and no tax is levied on the disposal of fund assets in Canada.
The Elimination of Double Taxation Article (Article 21) obliges the United Kingdom to give credit for Canadian tax paid only against UK tax computed by reference to the same profits, income or chargeable gains by reference to which the Canadian tax is computed. Since no UK tax is computed by reference to the subject of Canadian tax,that is, the withdrawal, no tax credit relief is allowable.
Similarly, where the disposal of fund assets to facilitate a withdrawal gives rise to a UK tax charge, no tax credit relief is allowable since the disposal does not attract a tax charge in Canada. 
DT4605 - Double Taxation Relief Manual: Guidance by country: Canada: Notes
Thank you.

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