Gary C

I assume DWP has sent you form CFN901 to complete to tell them about your non-UK pensions, so they can set the ball in motion. In theory it shouldn't take too long as they exchange all information electronically but DWP will need something like 6 to 8 weeks to get the process going and Germany may take about 3 or 4 months to their normal timetable. I applied for mine about 5 months before the start date, so it could be paid on time at the end of the first month (which is the first full month following your birthday as they do no apportion month 1). DRV will inform RiA and you will get a Tax Identification Number at some point from a central office but RiA will also give you a Steuernummer. I informed RiA as soon as I knew I would be getting the German pension, even though there isn't much to do until the end of the tax year in December. There isn't really any reason to delay and you can all of the forms about communicating by email, paying by direct debit and asking RiA to assess you absent tax returns all set-up before the end of the year. The RiA website has a lot of info and forms in English and that side of things ran quite smoothly. The DRV process shouldn't be too bad either, except they may well ask you for your post-17/pre-work education/training history to update that on your German records before doing the EU calculations to work out how much you will get.

Vinay6124/BarbaraS Scmidinger, I feel your pain and all I can suggest is you send a self assessment return voluntarily/unprompted to HMRC for the year in question, which is what we decided to do because of the unacceptable HMRC delays in dealing with a simple request to check, sign and date stamp a form required for a foreign tax authority. Our self assessment showed UK tax £0 as the income was covered by the personal allowance but the German tax office in Neubrandenburg (I assume that would be yours too) was then happy with a printout of the self assessment part (not the whole return) and we adopted this approach going forward, until we could no longer make the election to be subject to unlimited tax treatment... Not ideal but puts the control back in your hands.

HMRC Admin 25 - why are you pointing Vinay6124 at SA guidance? The form they are talking about is a form from and needed by the German tax office once it has been signed and stamped by HMRC. If the person is in SA and has completed a tax return they can send their self assessment to Germany in lieu of the form they are trying to get you to sign and stamp.

HMRC Admin 20, That is correct but those years do not have to be only UK years. Under the EU regulations on the coordination of social security systems, which continue to apply for those covered by the EU Withdrawal Agreement, xk5ukb473's Italian and UK years would be aggregated and if they then exceed 10, a UK pension based on their 8 years would be payable in addition to any Italian pension they may in due course be able to claim, applying the same aggregation regulations.

As a slight aside, have you looked at the US Windfall Elimination Provisions? Under certain circumstances, I think they can result in US pension benefits being reduced because a person has pension income from overseas. This could undo some of the benefit you would otherwise foresee from increasing your UK state pension by paying voluntary NI. Worth researching before you commit to paying UK NI.

Thank you. So the message is for people just to make sure they notify HMRC or the Finanzamt accordingly but the treaty itself does not foresee both countries taxing pensions.

Thanks but that doesn't really answer my question. We are talking here about the UK/German treaty and pensions, not some random form of income. HMRC Admin 19 said "If you have any other German pension then this could be taxed In both countries and you would then claim relief for the foreign tax paid." So, under what circumstances could a pension falling within the UK/Germany treaty fall to be taxed in both countries given the wording of Articles 17 and 18?

Can I ask under what circumstances a pension can be taxed in both the UK and Germany? Article 17(1), (2), (3) and (4) all refer to pensions being taxed only in one country or the other, as does Article 18(2). Is there soe other provision that could lead to them being taxed in both countries?

The contributions are not treated as paid in the other county but that fact that you have contributed means that the year can help you get past the required 10 years in the UK. If you have only 5 UK years and 20 NZ years, you would still only get 5 years' worth of UK pension. NZ would do a similar calculation using their rules, so your 5 UK years would help satisfy any NZ years' requirements but your NZ pension would still be based on your 20 NZ years

fluffymorson Middleton I wonder whether 2 issues are being conflated here. I may be wrong but I do not believe there is a mechanism for social security contributions paid in NZ to be treated as paid in the UK. However, there is a social security agreement between the 2 countries that seems to work in a similar way to the agreement between the UK and the EU for those covered by the EU Withdrawal Agreement. i.e. if you do not have the minimum 10 UK NI years to qualify for a UK state pension, years contributed in NZ can be added to your UK years to help you achieve that requirement. Your UK pension would then be based on your actual UK years, even though that is fewer than 10. If you already have 10 UK years then aggregation of your UK and NZ years would have no impact on your UK pension. Similarly, your UK years can help you reach similar qualifying criteria in NZ. You can of course pay voluntary UK NIC to fill those gaps in your UK record if doing so would actually increase your UK pension forecast but you would need to speak with DWP Future Pension Centre to establish where you stand on that.