Double Taxation Treaty - Philippines

Hi, I wonder if you can help me. I have looked at the double taxation treaty with Philippines and am confused as to article 17 referencing pensions. It says that "pensions and other similar remuneration paid in consideration of past employment to a resident of a Contracting State shall be taxable only in that State." My friend is resident in Philippines and has a UK private pension that is not occupational. Does this mean it is exempt from UK tax? I'm not sure whether the article solely refers to just occupational pensions being exempt or in fact all private pensions including occupational pensions?

Hi,
Under article 17, the UK pension is not an occupational pension as you state this is a private pension and as such they have made private contributions to obtain this pension.
Thank you.

Not HMRC...this makes no difference...example, self employed person paying in to a SIPP is a private pension, only possible because of self employed earnings, but its not "occupational"...the DTA follows most others, pensions are generally assessable in the country of tax residence, regardless of where paid from, unless "governmental" where the situation may be different...and this is the case here re the "private" pension, it is not liable in the UK, it is liable in the Phillipines, without relevant previous earnings it wouldnt have been possible to contribute so it is treated as if "occupational".