16
« Last post by GeordieBorn on February 06, 2019, 05:21:48 PM »
I’ve looked at this document a few times before, very good if you can’t sleep! It is horrible as it’s written to be read in either country. It uses those awful terms "a Contracting State" and "the other Contracting State". I believe Article 18 covers the state pension and (think) it’s saying your UK pension is only taxable in the UK. If you can keep awake and read some of the other taxable assets it seems to be using the term "the other Contracting State" where income from the UK could be taxed in Italy if you are fiscal resident there. I think royalties and interest are good/easy examples.
Reference to Article 19 is down to “state employment” and covers government private pensions and some local bodies’ pensions. I’m sure I read somewhere before that this was originally used for the likes of embassy staff, forces etc. but was expanded to cover more than that at some point.
I’m sure this could be read differently by many and I certainly would hate to have to argue any of this with HMRC, let alone the AdE in Italy.