Richard Bruton (Dublin North Central, Fine Gael)
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Question 54: To ask the Minister for Finance the tax position of a person who has retired to Ireland but owns certain pension rights in the US and the UK, countries which generate some annuity income. [9706/10]

Brian Lenihan Jnr (Dublin West, Fianna Fail)
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I am advised by the Revenue Commissioners that the taxation of annuities and pensions from superannuation funds in the USA and the UK is governed by the respective double taxation treaties between this country and those States.

Under the terms of both treaties, annuities and pensions arising from pension arrangements in the USA and the UK, are taxable only in the recipient's country of residence, with the exception of governmental pensions, which are broadly pensions paid by a State, local authority etc for services rendered in the discharge of functions of a governmental nature.

A "governmental pension" deriving from the USA or the UK is taxable only in those States unless the person in question is a resident and a national of this State, in which case it is taxable only in this jurisdiction.

US and UK social security pensions are taxable only in the recipient's country of residence.

I am also advised by the Revenue Commissioners that individuals who are resident but not domiciled in the State are liable to Irish tax on income arising outside the State only to the extent that such income is received in Ireland. This provision also applies to Irish citizens who are resident in the State but are not ordinarily resident here. However, section 8 of Finance Bill 2010 is proposing to withdraw such entitlement with effect from the tax year 2010.