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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
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
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
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.
Posted Fri, 03 Mar 2023 12:17:41 GMT by
Hi, I have a Swiss vested benefits account worth approx 18k CHF. I now live and work in the UK and I'm a British citizen aged 45. Can I transfer this Swiss pension to my UK personal pension plan? Are there any tax consequences? Thanks
Posted Tue, 07 Mar 2023 14:15:12 GMT by HMRC Admin 32

For free and impartial advice about the possible complications /implications of transferring your Swiss pension pot to a UK pension provider, HMRC recommends that you contact MoneyHelper.                                      

Transferring your pension                                              

Money Helper: Moving a UK pension overseas or moving an overseas pension to the UK          

Thank you.                                     
Posted Thu, 29 Jun 2023 13:53:19 GMT by Ian D
I have just moved from Switzerland to the UK and have my Swiss pension lump sum from when I left on May 31st 2023. There is a form that the pension trust in Switzerland need me to get stamped and then send back to them. Do you know where and how I go about getting the official stamp which I then need to send back to Switzerland? I already received the money in my Swiss account but plan to transfer it soon and close my Swiss account.
Posted Thu, 06 Jul 2023 07:54:32 GMT by HMRC Admin 20
Hi Ian D,

This is possibly a certificate of residence that is required - How to apply for a certificate of residence to claim tax relief abroad .

Thank you.

Posted Fri, 22 Sep 2023 11:40:14 GMT by Fiesta26 Emmi
Good morning HMRC, I would like to check something in relation to a Swiss Pension. I lived and worked in Switzerland from 1982-2001 and was a Swiss Tax Resident and National and in 2002 became a UK tax resident and remain one to date. If I were to cash in my vested benefit Swiss pension and receive a lump sum payment in my UK bank account after tax at source is deducted in Switzerland, and I subsequently use the money for a deposit on a property, would this amount be liable for UK tax? Reading the above posts and Article 18/19 of the 1977 Switzerland/UK DTA it would appear that I need not include this payment in my tax return under section "Overseas pensions, social security benefits and royalties etc." as the criteria of section 18.2 of the DTA are met: "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". Could you confirm that this still applies as the posts go quite a while back? Many thanks
Posted Mon, 25 Sep 2023 15:51:55 GMT by
HMRC I have a query related to my vested swiss pension currently being held in a Swiss bank account as a lump sum. I am a British citizen who lived and worked in Switzerland during 2003-2009 and have been back in the UK since.I am coming up to Swiss retirement age and able to withdraw the vested pension money and transfer to my British bank account. I understand that I am liable for tax in Switzerland. Will I need to declare or be taxed on my pension lump sum in the U.K too?
Posted Fri, 29 Sep 2023 11:42:24 GMT by marko182
Hi, My wife moved from Switzerland to the UK this week. She had already stopped paying into her Swiss pension prior, and they only require some documents for her to withdraw the sum and deposit it into her Swiss bank account. One document in question is rather confusing and it would be great if some of the people here that have already gone through the process shared their knowledge on what would Switzerland accept as proof that she now lives in the UK. I know UK itself is pretty straightforward when it comes to proving your address. She has her spousal visa documents, I will be putting her on the bills and the tenancy, but I am not sure whether Switzerland would accept that. Thanks!
Posted Mon, 02 Oct 2023 10:37:28 GMT by HMRC Admin 32
Hi Fiesta26 Emmi,

Per Article 18 (2) of the Double Taxation Agreement between the UK and Switzerland - Switzerland: tax treaties - GOV.UK, Any lump sum pension payment is taxable only in Switzerland and would not need to be reported to the UK.

Thank you.
Posted Tue, 03 Oct 2023 12:10:19 GMT by HMRC Admin 32

Under Article 18 of the Double Taxaton Treaty, the lump sum is only taxable in Switzerland.

Thank you.
Posted Sat, 09 Dec 2023 12:08:52 GMT by
Hello HMRC I have a question / clarification. I have lived overseas working on a Swiss contract and paying into a Swiss Personal Pension scheme administered by Swiss Life and now by AXA. I am now returning to the UK (2023/24 is likely to be a split year tax wise). If I transfer the cash from my Swiss Personal Pension scheme to the UK what is the UK tax treatment? I think I understand from the Double Taxation Treaty that it will be UK tax free (Article 18.2). Second question - can I transfer this lump sum into my SIPP in the UK? Thanks a lot for any clarifications you can give,
Posted Fri, 15 Dec 2023 09:37:46 GMT by HMRC Admin 25
Hi D Mend,
There is no tax impication on the transfer of the cpaital.
Any interest or dividends that this then generates is taxable income.
The pension itself is only taxable in Switzerland under the terms of the double taxation treaty.
You would need to check with your SIPP as to whether payments can be transferred from abroad.
Thank you. 
Posted Wed, 03 Jan 2024 20:51:31 GMT by
Hi, I’m a U.K. citizen but have not been resident since 2007. I am about to leave Switzerland (not at retirement age yet) and need to make a decision on whether to withdraw the funds from my Swiss pension fund or leave them in a frozen account with the pension provider. If I withdraw them and pay the money into a U.K. bank account after relocating back to the U.K., does this mean that the funds are taxable in the U.K.? Or only in Switzerland through the withdrawal tax?
Posted Wed, 10 Jan 2024 16:28:50 GMT by HMRC Admin 32

If you are resident in Switzerland in the tax year in which you withdraw funds from your tax return, you will be subject to Swiss taxes and not UK taxes.

If you are resident in the UK at the time, you will be liable to UK tax and not Swiss taxes.  

You would have to request a certificate of residence using link below, to give to the Swiss tax authorities, along with any other forms they would require, to claim back any tax they may have deducted.  

How to apply for a certificate of residence to claim tax relief abroad

Have a look at article 18 of the UK / Swiss tax treaty for more information.  

1977 Switzerland/UK Double Taxation Convention as amended by the 2009 Protocol

Thank you.
Posted Mon, 29 Jan 2024 15:42:52 GMT by
Dear HMRC My context.... As of January 29th, I am currently living in Switzerland and plan to return to the UK before the end of this UK tax year, ie before April 5th 24. According to the HMRC online residency test, I am a non resident for the UK 23/24 tax year. I plan to claim a lump sum payout of my pillar two pension from my Swiss pension provider before the end of the 23/24 UK tax year. I understand that under article 18.2 of the UK/Swiss DTT that this lump sum payment is to be taxed at source, ie in Switzerland only. That said, based on the various questions and responses in this forum, there appears to be some nuance as to when I claim, where I am residing when the amount is paid to me and to which countries bank account it is paid into. My questions.... • Presuming I claim the lump sum in this 23/24 UK tax year, does it make a difference to where I pay tax where I am residing when this lump sum is paid into my Swiss account, whether the UK or Switzerland ? • Presuming I claim the lump sum in this 23/24 UK tax year, does it make a difference to where I pay tax whether the amount is paid into a UK or Swiss bank account ? • Does it make a difference whether I claim the lump sum in this UK tax year (when I am a non-resident) or next year when I will be deemed a UK resident ? Kind regards Gray

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