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Posted Tue, 04 Jun 2024 09:01:03 GMT by Sophie Pudd
I wanted to clarify I have correctly understood the details of the DTA between the UK and Switzerland with regards to pension lump sums. My husband and I became Swiss residents in 2019 but have both moved back to the UK and are now UK residents. The Swiss Occupational Pension has to be taken out of the current scheme in Switzerland. It can be taken out as a lump sum and tax paid in Switzerland. We would like to transfer this money back to the UK. Are understanding based on Art 18.2 of the DTA as below is that the lump sum can be transferred without incurring tax in the UK, is this correct? Section 18 paragraph 2 'Notwithstanding the provisions of paragraph 1, a lump sum payment derived from a pension scheme established in a Contracting State and beneficially owned by a resident of the other Contracting State shall be taxable only in the first-mentioned State.' Kind regards
Posted Thu, 06 Jun 2024 12:49:17 GMT by HMRC Admin 19 Response
Hi,

Article 18(2) is advising that a lumpsum payment from a Swiss pension scheme, paid to a resident of the UK, is only taxable in Switzerland.

Thank you.

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