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P Weiser v HMRC

In P Weiser v HMRC (TC02178 – 22 August) an Israeli citizen (W) received a UK pension which was not taxed in Israel. HMRC issued a ruling that it was taxable in the UK. W appealed contending that it should be treated as exempt under Article XI of the UK/Israel double tax treaty. The First-tier Tribunal rejected this contention and dismissed his appeal. Judge Berner observed that Article XI(2) of the treaty provided that a pension ‘derived from sources within the United Kingdom by an individual who is a resident of Israel and subject to Israel tax in respect thereof shall be exempt from United Kingdom tax’. However W’s pension was not subjected to Israeli tax so it did not qualify for exemption from UK tax under this provision.

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Why it matters: Article XI of the UK/Israel double tax treaty provides...

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