DT4609 - Pensions: 1967 agreement

Article 16 of the 1967 agreement provided that a pension, including a governmental pension, received from sources in Canada by a resident of the United Kingdom was normally exempt from Canadian tax and subject to United Kingdom tax. If, however, the pension was a governmental pension and it was more favourable to a United Kingdom resident to do so, he could claim to be taxed in Canada and exempted from United Kingdom tax on the pension if

a) he was a resident of the United Kingdom on 6 April l965, and
b) the first payment period of the pension commenced before 6 April 1965, and
c) the pension was paid in respect of an employment the remuneration from which would have been exempt from United Kingdom tax.

There are similar provisions relating to governmental pensions paid to the surviving spouse or other dependants of an individual who died before 6 April 1965. These provisions are only to be applied for the years 1976-77 to 1980-81 (see DT4601) if they are more favourable to the individual than the provisions contained in the 1980 agreement (see DT4610).