HC Deb 17 December 1954 vol 535 c201W
Captain Kerby

asked the Chancellor of the Exchequer whether he is aware that retirement leave salary, which is often a condition of employment and always a reward for a lifetime of service abroad, is taxed at source overseas; that such retirement leave salary, already taxed at source overseas, if drawn monthly in Britain by a retired officer, is subject yet again to full British Income Tax but that, if accumulated abroad, it can be transferred to Britain at the end of the retirement leave period tax free; and what steps he proposes taking to right this injustice which penalises certain retired officers by making them subject to double taxation.

Mr. H. Brooke

An individual resident in the United Kingdom and entitled to emoluments from an employment abroad under an overseas employer is liable to United Kingdom Income Tax upon those emoluments to the extent that they are remitted to or received in this country at a time when the employment continues to be held: any remittances made after the end of the Income Tax year in which the employment has ceased are not, however, chargeable to United Kingdom Income Tax. To the extent that the income in question suffers tax both in the country of origin and in the United Kingdom, the taxpayer may claim credit for the overseas tax either under a double taxation agreement, if one exists, or under the provisions of Section 348, Income Tax Act, 1952. I do not think there is any injustice.