How UK Pension Income Is Taxed for Expats, by Country (2026)

When a UK pension is paid to someone living abroad, two countries can have an interest in the income: the UK, where the pension arises, and the country where the person now lives. Which one actually gets to tax it depends on the double tax treaty between the UK and that country, and on the type of pension involved.

The question of whether a UK pension is taxable abroad usually comes down to one distinction. Most treaties give the country of residence the right to tax private and occupational pensions, while UK government service pensions stay taxable in the UK. This article sets out how that works for six common destinations and how to stop UK tax being deducted at source.

The short version

• Under most UK treaties, private and occupational pension income is taxed only in the country where you are tax resident.
• UK government service pensions (civil service, armed forces, NHS, police, teachers, local authority) usually remain taxable in the UK.
• The UK State Pension is treated as ordinary pension income and follows the residence rule in most treaties.
• An HMRC NT (no tax) code lets your UK provider pay the pension without deducting UK tax once a treaty claim is approved.
• The NT code is requested through a DT-Individual form, certified by the tax authority in your country of residence.
• The UAE levies no personal income tax, so a UK private pension is effectively untaxed there once residence is established.

How treaties split the taxing rights

Most UK double tax treaties follow the same logic as the OECD model. One article deals with private pensions and one deals with government service pensions. For private and occupational pensions, the typical position is that the income is taxable only in the state of residence. So a French, Spanish, Australian or Portuguese resident generally pays tax on a UK occupational or personal pension in that country, not in the UK.

Government service pensions are treated separately. These are pensions paid for past service to the Crown or a public body, covering ex civil servants, armed forces, police, firefighters, teachers, local authority staff and similar roles. The usual treaty position is that these remain taxable only in the UK, regardless of where the recipient lives. A narrow exception applies in some treaties where the person is both resident and a national of the other country, in which case that country may tax instead.

The UK State Pension is not a government service pension for treaty purposes. It is treated as ordinary pension income, so in the treaties below it follows the residence rule.

Where UK pension income is taxed, by country

The table summarises the treaty position for private or occupational pension income and for the UK State Pension, alongside the position for UK government service pensions. Positions are general and depend on confirmed tax residence and the treaty in force at the time.

Two points need care. In the USA, periodic pension payments are taxed in the country of residence, but lump sums are allocated to the country where the scheme is established, and the treaty savings clause means a US citizen can still face US tax even where the UK treats part of a withdrawal as tax free. In Portugal, the new UK-Portugal treaty signed in September 2025 takes effect in Portugal from 1 January 2026 (and for UK income tax from 6 April 2026); private pensions and the State Pension are taxed in Portugal, while government service pensions stay with the UK. Portuguese domestic rules, including any non-habitual resident status held from before that regime closed, then determine the actual rate applied.

The NT code and the DT-Individual form

By default a UK pension provider deducts income tax under PAYE. If a treaty gives the taxing right to your country of residence, you can ask HMRC to issue an NT (no tax) code so the pension is paid gross from the UK. Without it you may have UK tax deducted that you then have to reclaim.

The route is the relevant DT-Individual form for your country (for example DT-Spain Individual or DT-France Individual). You complete the form, then have it certified by the tax authority in your country of residence to confirm you are tax resident there. HMRC reviews the claim and, where it agrees, sends an NT code directly to your pension scheme. The income is then declared and taxed in your country of residence under that country's rules. Government service pensions are not covered by this relief, because the UK keeps the taxing right.

Confirmed tax residence is the foundation of every position above. Tax residence is decided by each country's own rules and, where you might be resident in both, by the treaty tie-breaker. None of this changes your obligation to report the income correctly in your country of residence.

This article is for general information only and does not constitute financial, tax or regulatory advice. Kaeltripton.com is not authorised or regulated by the FCA. Pension and tax rules differ by country of residence and change over time. Verify any figure with official sources such as GOV.UK, HMRC or the FCA, and take advice from a suitably authorised adviser in your country of residence before acting.

FAQ

Is my UK pension taxable abroad or in the UK?

For private and occupational pensions, most UK treaties give the taxing right to your country of residence, so the income is taxed there rather than in the UK. UK government service pensions are the main exception and usually stay taxable in the UK.

Why is my UK civil service or NHS pension still taxed in the UK?

Government service pensions, including civil service, armed forces, police, teachers and NHS schemes, are treated under a separate treaty article that normally keeps the taxing right with the UK, regardless of where you live. A limited exception can apply if you are both resident and a national of the other country.

How do I stop UK tax being deducted from my pension?

Where a treaty gives the taxing right to your country of residence, you can apply for an HMRC NT code using the relevant DT-Individual form. The form must be certified by the tax authority in your country of residence, after which HMRC can instruct your provider to pay the pension gross.

Is the UK State Pension treated like a government pension?

No. For treaty purposes the UK State Pension is ordinary pension income, not a government service pension, so in the treaties covered here it follows the residence rule and is taxed in your country of residence.

Does the USA position differ from the others?

Yes. Periodic pension payments are taxed in the country of residence, but lump sums are allocated to where the scheme sits, and the treaty savings clause means a US citizen may still face US tax even where the UK treats part of a withdrawal as tax free.