Reporting Canada RRSP

Hello HMRC Admin, I have a question related to the UK tax treatment of a Canadian Registered Retirement Savings Plan (RRSP). In this scenario I am a UK Resident for income tax purposes, domiciled in Canada but a Canadian Non-Resident. I will be taxed on the Arising Basis. My question is: Do the capital gains, dividends, etc. that are generated inside a Canadian RRSP need to be reported as foreign income in a self-assessment? In Canada the income generated is not subject to taxation so no income tax return is filed with the Canada Revenue Agency. As an extension to the question: How would income generated in a Tax Free Savings Account (TFSA) or First Home Savings Account (FHSA) be treated? Are these types of accounts viewed as non-registered accounts where capital gains and dividends are reported as foreign income?

Hi John Smith,
The guidance at DT4617, advises that
'Where a UK resident makes a lump sum withdrawal from an Registered Retirement Savings Plan (RRSP) or an Registered Retirement Income Funds (RRIF), Canada imposes a 25 per cent withholding tax'.
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. 
Thank you.

Thank you for the response HMRC Admin. I was aware of the CRA withholding tax on non-resident withdrawals, as well as the fact that there is no tax credit offered by HMRC due to the difference in tax events defined at https://www.gov.uk/hmrc-internal-manuals/double-taxation-relief/dt4617. However, what I am actually asking is whether any capital gains and dividends generated inside the RRSP will be subject to UK income tax and need to be reported. In Canada that income is not taxable, since it is a tax-free account. Note that I am talking about the income generated before retirement and before withdrawal of any funds. There is no withdrawal of funds from the account in this scenario. Any dividends will be reinvested within the account for many years before withdrawal. Any proceeds from the disposition of assets will be used to buy other assets within the account and held for many years before withdrawal.

Hi John Smith,
It is only at withdrawal that liability to tax would occur.
Gains within the RRSP, would not be subject to UK tax.
Thank you. 
 

Thanks HMRC Admin. Would you be able to point me to any documentation that states that tax liability would only occur on withdrawal from the RRSP? Is there no tax liability on income generated in the account because the account is recognized as a foreign pension? I am curious how a similar scenario would be treated with other registered Canadian accounts, such as for Tax Free Savings Accounts (TFSA) and First Home Savings Accounts (FHSA). Would these accounts only produce a tax liability upon withdrawal of funds as well?

Hi John Smith,
The guidance at DT4617, advises that 'Where a UK resident makes a lump sum withdrawal from an Registered Retirement Savings Plan (RRSP) or an 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. 
It is only the retirement savings plans or registered retirement income funds that would be covered by DT4617.  
If you are a UK resident, you are taxable on the TFSa and FHSA in the UK, under world-wide income.
Thank you.