Market leading insight for tax experts
View online issue

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.

Read the decision

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

If you or your firm subscribes to Taxjournal.com, please click the login box below:

If you do not subscribe but are a registered user, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this article in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
EDITOR'S PICKstar
Top