Percival v Revenue and Customs: FTTTx 18 Apr 2013

FTTTx INCOME TAX – Taxpayer a British national resident in the Republic of Ireland – taxed in the UK on a civil service pension by virtue of Article 18 UK/Irish Double Taxation Convention – taxpayer’s wife an Irish national taxed on UK local authority pension in Ireland – taxpayer taxed less favourably in the UK than if taxed as his wife in Ireland – whether Article 18 DTC compatible with EU law – discrimination on grounds of nationality – whether Article 18 DTC compatible with Article 14 of the European Convention on Human Rights – construction of Article 23(1) of the DTC (non-discrimination clause) – appeal dismissed

Citations:

[2013] UKFTT 240 (TC)

Links:

Bailii

Income Tax

Updated: 05 December 2022; Ref: scu.491868