Provisions are to be introduced to the Finance (No. 3) Bill on the subject of overseas pensions to prevent foreign pensions received by UK residents being protected by a double taxation agreement. The idea is not to undermine the double taxation network but to prevent UK residents deliberately transferring their pension funds into a pension scheme in a country which has a favourable double taxation agreement with the UK providing for exemption from tax in the UK on their pension.

It will be interesting to see how this develops. The intention is clear enough, but I thought that double tax agreements generally prevailed over the domestic legislation (and in any event, you surely cannot go round amending the terms of a treaty unilaterally) so I wonder how this is going to be brought into effect.