2001 US-UK Income Tax Convention / IRS Form 1116 / HMRC SA106
US-UK Tax Treaty Guide
An exhaustive legal analysis of the 2001 US-UK Income Tax Convention—covering Article 17 pensions, Article 10 dividends, IRS Form 1116, and HMRC SA106 claims.
Treaty Structure & Statutory Provisions (SI 2002/2848)
Convention Between the UK & the United States (2001)
The US-UK Income Tax Convention (enacted in the UK via Statutory Instrument 2002 No. 2848) governs tax jurisdiction over dual US-UK taxpayers.
Key articles include Article 10 (Dividends 15% WHT cap), Article 17 (Pensions & Annuities), Article 18 (Social Security payments), and Article 24 (Relief from Double Taxation via Foreign Tax Credit Relief).
Key Treaty Parameters:
| UK Enactment | SI 2002/2848 |
| IRS Credit Form | Form 1116 / FEIE 2555 |
| Dividend WHT Cap | 15% (Article 10) |
| Pension Primary Tax | State of Residence (Art 17) |
| HMRC Schedule | Self Assessment SA106 |
US Foreign Tax Credit Relief Calculator
US-UK Tax Treaty Estimator
Enter US dollar income and IRS tax paid to calculate your foreign tax credit on UK tax returns.
Frequently Asked Questions (FAQ)
Under Article 17(1)(a) of the 2001 US-UK Income Tax Convention, pensions and annuities paid to a resident of one country in consideration of past employment are taxable only in the state of residence.
Under Article 10 of the Treaty, dividend withholding tax charged by the IRS on US company stock dividends paid to UK residents is capped at 15% (reduced to 0% for qualifying corporate parent entities).
US citizens living in the UK pay UK Income Tax first to HMRC. They then claim a dollar-for-dollar Foreign Tax Credit on IRS Form 1116 against their US federal tax liability under Article 24 of the Treaty.