Update - International taxes on pensions

19 September 2023      Julia Ascott, Employment Taxes Specialist

Back in May this year, we published Vialto guidance on the tax/social security/reporting obligations for continuing pension contributions (into typically the USS) whilst employees are working overseas. BUFDG commissioned 10 countries for this guidance document and will continue to pay for annual maintenance charges to ensure the guidance is kept up to date.

Universities have contacted both BUFDG and Vialto to ask whether further countries can be added. We therefore arranged a follow up Time to Talk roundtable with interested members and Vialto, held 19 September, to discuss additional countries, other queries and next steps.

Additional countries

Existing countries

The initial guidance included:

  • Australia
  • Belgium
  • China
  • France
  • Germany 
  • India
  • Italy
  • Netherlands
  • Switzerland
  • USA

Additional countries already produced

Vialto have confirmed that they have already produced guidance for universities for the following countries:

  • Austria
  • Canada
  • New Zealand
  • Portugal
  • South Africa
  • Spain
  • Sweden

Universities who are interested in purchasing these country guides can do so by contacting Vialto will share the fee for each territory between all contracting parties. That means the more interest, the cheaper the territory. For those universities who have already paid for the country guide, Vialto will issue a credit note.

The country guides are commissioned on an annual basis but you can discuss the fee position with Vialto for more details.

Other countries

During the Time to Talk discussion on 19 September, the following countries were also requested:

  • Norway
  • Ireland
  • Greece
  • Singapore
  • Spain

The most common request was Ireland and BUFDG will look into whether we can directly commission this report from Vialto. The remaining countries should be discussed directly with Vialto.

Additional queries

There were queries relating to the first 10 countries and whether we could gain specific advice on:

  • Netherlands relief - can 'corresponding approval' be sought for the sector as a whole - Vialto confirmed that one university is looking into this (BUFDG to speak with them to support) and the decision would help universities as a whole to know whether it was available, but the approval would need to be applied for by each university
  • The conditions to consider under treaty relief and how to determine whether income might fall within Article 14 or the specific pensions article
  • Could USS be confirmed by each jurisdiction as a recognised pension scheme

Next Steps

Rectification of any issues are being considered by each university. Members questioned how, as a sector, could these messages to individuals be put forward and aligned with other universities. BUFDG will include as an agenda item on the next International Committee meeting (due in November 2023).

All interested members were asked if they would like continual updates on the above, either via further roundtables or emails - the majority were happy with either. BUFDG will therefore keep members updated via email (email if you would like to be included on this) and arrange follow up roundtables at appropriate intervals.

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