Income Tax (Earnings and Pensions) Act 2003 section 646A

Foreign pensions of consular employees

Section 646A provides an income tax exemption for foreign pension income received by consular officers and employees working in the UK on behalf of a foreign state, provided certain nationality, employment and residency conditions are met.

  • Foreign pension income of a consular officer or employee in the UK is exempt from income tax where an Order in Council has been made giving effect to a reciprocal arrangement with the relevant foreign state
  • The officer or employee must not hold British citizenship (including British overseas territories citizenship, British National (Overseas) status or British Overseas citizen status) and must not carry on any other trade, profession or employment in the UK beyond their consular role
  • The officer or employee must either be a permanent employee of the foreign state or must not have been ordinarily resident in the UK immediately before taking up the consular post
  • Foreign pension income for these purposes covers foreign pensions, certain employment-related annuities sourced outside the UK, pre-1973 overseas pensions and voluntary annual payments from non-UK sources

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