UK-Argentina double tax treaty: pensions, rent and relief

A pensioner moving from Britain to Argentina may receive several UK payments that need separate treaty analysis. A qualifying former-employer pension is normally taxable only in Argentina once the recipient is treaty-resident there. UK rental profit can remain taxable in both places, with relief limited to eligible tax actually charged. Confirm the classification of a State Pension or a particular pension withdrawal before claiming relief. Those rules come from the 1996 UK–Argentina convention, in force since 1 August 1997; the bank account receiving the money does not decide which country taxes it.

Tax residence comes before the pension article

Each country first applies its own residence rules. HMRC's Statutory Residence Test measures UK days, work and ties across a tax year from 6 April to 5 April. For a foreign national, obtaining permanent immigration residence or completing 12 months under temporary authorisations generally triggers Argentine tax residence, subject to exceptions and absence rules. Article 116 makes that status effective from the start of the following month. Argentine residents generally report worldwide income for Ganancias (income tax). Compare the Argentine residence triggers and calculate UK days and ties against the dates of the payments.

If both domestic systems treat you as resident, Article 4 tests a permanent home first, then the centre of personal and economic ties, habitual abode and nationality, with agreement between the authorities last. Having access to a house in each country makes the later tests especially relevant. Family location, nights spent in each country and work and financial connections help establish the picture. Argentine treaty residence can limit UK tax on a particular pension while leaving UK filing duties and UK property income within the UK system.

The treaty gives different answers for different income

The allocations below assume Argentine treaty residence. When the treaty says the UK may tax a receipt, domestic allowances and exemptions still determine whether any UK tax is due.

Article 2 defines the covered taxes. The convention is not a social-security agreement for UK National Insurance or Argentine social contributions, and Article 2 expressly includes Argentina’s personal assets tax. Bienes Personales still needs a domestic assessment alongside any relevant treaty capital provisions. For other UK obligations after departure, see UK tax after leaving.

A workplace pension paid for past employment, or an annuity meeting Article 18, belongs to Argentina for an Argentine treaty resident. A provider may continue deducting UK PAYE until HMRC processes a claim. A SIPP (self-invested personal pension) needs to be classified from its scheme and payment terms rather than its label; Article 19 expressly excludes pensions, so a government-service pension meeting Article 18’s past-employment conditions follows that pension article.

Whether your UK State Pension is treated like a workplace pension or falls under a different treaty article is not something to assume. Confirm its classification and relief with HMRC and your Argentine tax adviser before relying on an exemption or tax-credit calculation. The full new 2026/27 rate is £241.30 weekly, £12,547.60 for 52 weeks before personal adjustments. Annual increases are frozen while a recipient lives in Argentina; an existing award may be below that full UK rate. Plan your State Pension abroad with your own award rather than the headline figure.

A lump sum representing qualifying past-employment pension remuneration can also fall under Article 18, but its domestic Argentine tax treatment needs separate calculation. The UK's 25% pension commencement lump sum treatment does not create an equivalent Argentine exemption. Flexi-access taxable payments, pension commencement lump sums and transfers have different characteristics and dates; check SIPP withdrawal choices before fixing a withdrawal amount.

A pension and rental flat in the same tax year

Consider two British spouses established as Argentine treaty residents in a 2026/27 planning illustration. One receives the full new State Pension, £241.30 weekly or £12,547.60 over 52 weeks, and owns a UK flat with £8,000 rental profit after deductible costs. The other has a qualifying former-employer pension of £18,000 a year. One spouse holds a SIPP but draws no income from it during the year.

Article 18 assigns the £18,000 employment pension to Argentina, with UK PAYE relief claimed by its recipient. For this illustration only, suppose HMRC confirms that the recipient's State Pension and UK rent remain within the UK tax charge and Argentina requires both to be reported. If the recipient has a full £12,570 UK personal allowance and no other relevant income beyond those payments, only £22.40 of the allowance remains for rent. The other £7,977.60 of rental profit would attract £1,595.52 at an assumed 20% UK basic rate. That State Pension bears no UK tax after the allowance, so its Argentine credit on that income is zero.

Suppose the Argentine tax attributable to the rent is the sterling equivalent of £2,100 under the filing year's currency rules. A £1,595.52 credit leaves £504.48 equivalent Argentine tax on that rent. If attributable Argentine tax were instead £1,200, the credit would stop there; Argentina would not refund the other £395.52 of UK tax. Actual allowances, ownership shares, currency dates and Argentine bands change the numbers. The unwithdrawn SIPP is not pension income just because its value rises, although Argentine asset-tax rules may still matter.

Claiming relief without confusing the forms

Departure and treaty relief happen on different paperwork. Someone who does not normally file Self Assessment may report a qualifying departure on P85. Self Assessment filers normally report their residence position on SA109; neither route by itself stops pension PAYE. UK residence is assessed over the relevant 6 April–5 April tax year, and a dual-residence period calls for Article 4 evidence. There is no universal treaty rule under which a move of 183 days settles every residence question. UK tax after leaving explains the employment cases in which P85 must accompany the return.

ARCA (Agencia de Recaudación y Control Aduanero, formerly AFIP) offers a free online certificado de residencia fiscal through a clave fiscal tax-account login. Its covered period should match the payments for which relief is sought; HMRC may ask for a translation. The official DT-Individual form is the HMRC claim for relief at source or repayment of UK tax on eligible income. Its instructions cover certification, payment details and years; the pension scheme's PAYE evidence may be needed. Deduction can continue while HMRC considers the claim.

A UK letting still has its own paperwork. Under the Non-Resident Landlord Scheme, form NRL1 can seek approval for rent to be paid without agent or tenant withholding, but the landlord still calculates final UK tax. See the NRL1 process. Pension statements, the final UK tax assessment, conversion evidence and Argentine Ganancias records establish any credit more reliably than an agent's deduction alone. ARCA lists its tax-residence certificate as free. Use the official HMRC forms and check the status of any pending relief claim. A non-resident sale of UK residential property raises a separate UK 60-day capital-gains reporting and payment rule, even where an allowance covers the eventual gain.

Withholding limits, later changes and disputes

For a beneficial owner meeting the treaty conditions, Articles 10–12 cap source-country withholding. Dividends are capped at 10% for a company holding at least 25% of the payer's voting power and at 15% otherwise, including for individuals. Interest has a 12% cap; royalties have 3%, 5%, 10% or 15% caps depending on the right or work. Domestic law may impose less, and UK company dividends generally carry no UK withholding. A 15% treaty dividend ceiling therefore does not mean every UK dividend has tax deducted.

Article 23(2) caps an Argentine resident's credit for UK tax at the Argentine tax attributable to the same income; UK residents claiming credit for Argentine tax also face domestic and treaty limits. Excess withholding above a treaty ceiling is recovered from the country that withheld it, rather than through an unlimited credit in the residence country. A UK resident seeking lower Argentine withholding can obtain an HMRC Certificate of Residence and follow the payer's or ARCA's process. An Argentine resident seeking UK treaty relief instead uses Argentine residence proof and the relevant UK claim.

The convention took effect for Argentine tax on 1 January 1998 and for UK income and capital gains tax on 6 April 1998. Multilateral Instrument (MLI) amendments apply to withholding taxes in both countries from 1 January 2026, to other Argentine taxes from 1 January 2027 and to UK income and capital gains tax from 6 April 2027. Their principal-purpose test can deny a benefit where obtaining it was one of an arrangement's principal purposes. The official treaty and MLI text matters particularly for a company restructuring or large distribution.

If an authority taxes a person contrary to the convention, Article 26 provides a mutual agreement procedure (MAP). Its MLI-modified text permits a case to either competent authority and specifies three years from the first notification of treaty-inconsistent taxation; check the amendment’s effective date for the taxes involved. Keep assessments, payments and residence evidence to support it. Ordinary payment and appeal deadlines still run. A British citizen seeking immigration permission, rather than a tax-residence answer, needs the Argentina visa guide. The treaty is most useful when each receipt has its own classification and the same year's actual tax is traced through both returns.

If you become an Argentine citizen

British readers considering Argentina's citizenship by investment programme should take UK and Argentine tax advice before moving or committing funds. Our citizenship by investment guide for UK citizens sets out questions to verify before committing funds.