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Posted Sat, 16 Sep 2023 16:39:29 GMT by Jestyn thirkell-white
Hi If I have a SIPP in the UK but am resident in Switzerland, if I: a) take 25% tax free it is not taxed in Switzerland (Art 18.2 of the Swiss / UK double taxation agreement says lump sums are taxed in the country they are paid b) If I then take small annual amounts out as drawdown (say 4% of the remainder), are they i) taxed in the UK (because they are small lump sums do fall under 18.2 again) or ii) taxed in Switzerland because they are income? Would be very grateful for some guidance. Thank you! Jestyn
Posted Tue, 19 Sep 2023 07:18:04 GMT by Jestyn thirkell-white
Should really read my post before pressing send... "they are small lump sums SO fall under 18.2 again"

Posted Tue, 26 Sep 2023 17:53:12 GMT by HMRC Admin 10
If you dont meet the conditions of Article 19, then the small annual amounts you then take are taxable in the UK as this is seen as a recurring pension and not a one off lump sum.
Posted Tue, 26 Sep 2023 18:45:51 GMT by Jestyn thirkell-white
Oh, I'm sorry, you've really confused me. If it is a "recurring pension", shouldn't it be taxed where I live (in Switzerland), not in the UK? I live in Switzerland: lump sums paid in the UK are taxed there, regular pension income is taxed in Switzerland. But you've replied that because they are regular income not lump sums they are taxed in the UK. That isn't right is it?
Posted Thu, 05 Oct 2023 10:35:44 GMT by HMRC Admin 25
Hi Jestyn thirkell-white,
The previous replies were issued based on you being a UK tax resident and the pensions being from Switzerland.
As UK pensions they will automatically be taxed in the UK but you can submit a claim under double taxation relief so that a code of NT is issued for you to then declare them in Switzerland:
Double Taxation: UK-Switzerland (Form Switzerland-Individual)
Thank you. 
Posted Thu, 05 Oct 2023 10:43:31 GMT by Jestyn thirkell-white
Thank you. That's clearer, although I'm not sure why it wasn't clear where I lived: the first line of the first post says "If I have a SIPP in the UK but am resident in Switzerland:" 1) So, to confirm if I am a) resident in Switzerland b) Have a UK SIPP c) take small regular lump sums I can apply for an NT code, not get taxed on them in the UK, and declare them and pay tax on them in Switzerland. 2) What is the criteria for what attracts lump sum treatment vs pension treatment? Some percentage of the total fund? How regularly I take the amounts? Frequency of withdrawals? Thank you!
Posted Tue, 10 Oct 2023 11:26:01 GMT by HMRC Admin 32

Yes. As you are resident in Switzerland and have a UK SIPP. You can claim a NT tax code by submitting a validated DT individual UK/switzerland form.

Double Taxation: UK-Switzerland (Form Switzerland-Individual)

Article 18(2) covers lumps sums and advises they are taxable only in the UK.

Thank you.

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