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Double tax treaty relief
Tie-breakers, pension articles and reliefs claimed in the right country, in the right order — none of it happens automatically.
Relief claimed in the right place, and the right order.
The US–UK treaty is what stops a cross-border life being taxed twice. It does nothing on its own: every relief has to be claimed, on the right form, against the country the treaty says must give way.
Sequencing matters as much as eligibility.
What we do
01
Residence tie-breakers
Where both countries claim you as resident, the treaty decides. We establish and document which way it falls.
02
Treaty-based return positions
Form 8833 disclosures where a position depends on the treaty rather than domestic law.
03
Pension articles
The treatment of contributions, growth and drawdown under the articles that deal with retirement savings.
04
Relief ordering
Deciding which country taxes first, so credits are available rather than stranded.
Why us
Eligible is not the same as claimed
Plenty of people qualify for relief they never receive, because nobody made the claim or made it in the wrong jurisdiction.
We document the basis for each position so it survives being questioned years later.
When it comes to questions that cross two tax systems, you need specialists who work in both every day. Meet the team that make it happen.
View our peopleFrequently asked
Does the treaty mean I only pay tax once?
It is designed to prevent double taxation, but only through claims you actively make. Left alone, both systems will tax the same income.
Can the treaty stop me having to file?
No. It allocates taxing rights; it does not remove filing obligations. US citizens file regardless of where they live.
What does the tie-breaker actually do?
Where both countries treat you as resident, it allocates treaty residence to one, working through permanent home, centre of vital interests, habitual abode and nationality in order.
What is the saving clause?
A provision letting the US tax its citizens as though much of the treaty did not exist. It is why US citizens get less from the treaty than people expect, subject to listed exceptions.
Do I have to disclose a treaty position?
Often yes, on Form 8833. Some positions are exempt from disclosure, but taking one silently where disclosure is required carries its own penalty.
Does the treaty cover state taxes?
No. States are not party to it and many disregard it entirely, which is a frequent and expensive surprise.
Tie-breakers, pension articles and reliefs claimed in the right country, in the right order — none of it happens automatically.
Key contact
Tell us what you are trying to solve and we will put the right specialist on the call.
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