Macklin: World Bank pensions and treaty interpretation

Article 31 of the Vienna Convention on the Law of Treaties requires a treaty to be interpreted in accordance with the ordinary meaning of its terms in their context and in the light of the treaty’s object and purpose. The Upper Tribunal applied these principles to conclude that the World Bank pension scheme is established in the United States. As a result, the US/UK tax treaty grants partial exemption on pensions paid to the World Bank’s former employees who are UK resident. In light of the tribunal decision, employees and former employees of international organisations should re-evaluate their tax treatment, as error claims may result in the repayment of overpaid tax