UK Pension tax liability- Retired Irish tax resident

Article 18:
1) Remuneration or pensions paid by, or out of funds created by, Ireland or a local authority
thereof to any individual in respect of services rendered to the Government of Ireland or a
local authority thereof, in the discharge of functions of a governmental nature, shall be
taxable only in Ireland unless the individual is a United Kingdom national without also being
a national of Ireland.
(2) Remuneration or pensions paid out of public funds of the United Kingdom or Northern
Ireland or of the funds of any local authority in the United Kingdom to any individual in
respect of services rendered to the Government of the United Kingdom or Northern Ireland
or a local authority in the United Kingdom in the discharge of functions of a governmental
nature, shall be taxable only in the United Kingdom unless the individual is a national of
Ireland without also being a United Kingdom national.
(3) The provisions of paragraphs (1) and (2) of this Article shall not apply to remuneration or
pensions in respect of services rendered in connection with any trade or business.


What does the final clause at the end of section (2) mean?

shall be taxable only in the United Kingdom unless the individual is a national of
Ireland without also being a United Kingdom national.
 
Protocol said:
Article 18:
1) Remuneration or pensions paid by, or out of funds created by, Ireland or a local authority
thereof to any individual in respect of services rendered to the Government of Ireland or a
local authority thereof, in the discharge of functions of a governmental nature, shall be
taxable only in Ireland unless the individual is a United Kingdom national without also being
a national of Ireland.
(2) Remuneration or pensions paid out of public funds of the United Kingdom or Northern
Ireland or of the funds of any local authority in the United Kingdom to any individual in
respect of services rendered to the Government of the United Kingdom or Northern Ireland
or a local authority in the United Kingdom in the discharge of functions of a governmental
nature, shall be taxable only in the United Kingdom unless the individual is a national of
Ireland without also being a United Kingdom national.
(3) The provisions of paragraphs (1) and (2) of this Article shall not apply to remuneration or
pensions in respect of services rendered in connection with any trade or business.


What does the final clause at the end of section (2) mean?

shall be taxable only in the United Kingdom unless the individual is a national of
Ireland without also being a United Kingdom national.
Click to expand...
Mind boggles
 
@jpd

My reading of Article 18 suggests that public service pensions (both NI State Pension and PS occupational pensions) from a UK public service employment are only taxed in the UK, and not taxed in Ireland, UNLESS the person is Irish.

To my reading, this means public pensions received by a UK national living in Ireland are not taxed by Ireland.

Is that your interpretation of Article 18?
 
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