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Posted Thu, 24 Nov 2022 12:16:08 GMT by HMRC Admin 32

If the pension was paid prior to you returning to the UK you will need to consider split year treatment.

If you qualify for split year then you only report any foreign income for the UK part of the year.

RDRM12000 - Residence: The SRT: Split year treatment

If you do not qualify then you will need to report all your foreign income to the UK

Tax on foreign income

The guidance at RDRM12150 below will help you work out if split year treatment applies.

RDRM12150 - Residence: The SRT: Split year treatment: Case 4: Starting to have a home in the UK only 

If this applies and you do not need to declare the pension then any capital you transfer will only be taxed if any interest is generated once it is in your account.

Thank you.
Posted Wed, 04 Jan 2023 20:49:46 GMT by Tim Wallace
Hi. I’m an Australian citizen living in France and working in Switzerland as a cross-border worker. I will be migrating to the UK in 2023 with my British wife. When I migrate (and cease work in Switzerland) I will access my Swiss pension as a lump sum. Does Art 18(2) apply equally to me in terms of my pension not being taxed in the UK? Thanks. Tim
Posted Wed, 04 Jan 2023 21:08:16 GMT by Tim Wallace
Sorry, a follow up question. If I choose to access my Swiss pension money as an annuity/monthly pension instead of withdrawing the capital as a lump sum, will that be taxed as income in the UK? And if yes, is it given any preferential tax treatment because it’s a pension? Thanks again
Posted Wed, 11 Jan 2023 10:09:44 GMT by
Hi Tim Wallace,

We cannot comment on future plans as legislation may change.

Thank you. 
Posted Wed, 11 Jan 2023 19:34:54 GMT by Tim Wallace
Thanks for the reply. I understand you cannot predict future law. However, based on the law as it’s interpreted today, if I were to migrate today, could you answer my two questions please? Thanks
Posted Wed, 25 Jan 2023 14:48:33 GMT by HMRC Admin 20
Hi Tim Wallace,

Based on the information you have provided, if you were to migrate to the UK today, Article 18(2) would apply if you accessed your Swiss pension as a lump sum; and Article 18(1)  would apply if you chose to access your pension by means of monthly payments (which would not be given 'preferential treatment'). 
1977 UK/Switzerland Double Taxation Convention as amended by the 1981, 1993, 2007, 2009 and the 2017 Protocols The 2017 Protocol entered into force on 16 July 2019                                                            
Income Tax: introduction

Thank you.

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