UK-USA Tax Treaty for UK Expats 2026 -- Tie-Breaker, Article 17 and Pension Rules
The UK expat tax treaty USA (2001 DTC) governs pensions, dividends and capital gains. Article 17 allows pension income to be taxed only in the country of residence -- but the US savings clause overrides this for US citizens. Finance Act 2025 introduced residence-based IHT.