DoubleTaxationUnited States – United Kingdom tax treaty: residence, 183 days, rates
Convention between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital gains (signed 24 July 2001, amended by the Protocol of 19 July 2002)
- Signed: 2001-07-24
- In force since: 2003-03-31
- Official text
If both countries treat you as resident
- A dual resident is deemed a resident only of the State in which he has a permanent home available to him; if he has a permanent home in both States, only of the State with which his personal and economic relations are closer (centre of vital interests). Art. 4(4)(a) of the Convention
- A U.S. citizen or green-card holder is a U.S. resident for treaty purposes only if he or she has a substantial presence, permanent home or habitual abode in the United States and is not a resident of a third State under that State's treaty with the UK. Art. 4(2) of the Convention
- If you have no permanent home available in either State, the treaty goes straight to habitual abode (the centre of vital interests step applies only where there is a home in both States). Art. 4(4)(b) of the Convention
- Habitual abode in both States or in neither — resident only of the State of which you are a national; national of both or neither — the competent authorities shall endeavour to settle the question by mutual agreement. Art. 4(4)(c), (d) of the Convention
Income: who taxes it
| Income | Treaty rule | Article |
|---|---|---|
| Salary (employment) | The country where the work is done may tax it. Exempt if all apply: no more than 183 days in any 12-month period; the employer is not resident there; the pay is not borne by its permanent establishment there. | Art. 14(2) |
| Self-employment, business, services | Country of residence; the other country only taxes profits of a permanent establishment (fixed base) there. | Art. 7 |
| Pension | Only the country of residence. | Art. 17(1)(a) |
| State pension (social security) | Only the country of residence. | Art. 17(1)(a) |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1)-(2) |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 19(1)-(2) |
| Rent from real estate | The country where the property is located may tax; the country of residence relieves double taxation. | Art. 6(1) |
| Dividends | Source country: at most 15%; the country of residence relieves double taxation. | Art. 10(2)(b) |
| Interest (deposits, bonds, loans) | Only the country of residence. Other rates or exemptions apply in some cases (see the article). | Art. 11(1) |
| Royalties (copyright, licences) | Only the country of residence. | Art. 12(1) |
| Sale of property or shares | Real estate: the country where it is located may tax. Shares of companies deriving their value mainly (over 50%) from real estate: the same. Other property: under certain conditions the source country may also tax (see the article). | Art. 13 |
| Other income | Only the country of residence. | Art. 22(1) |
How double taxation is relieved
- United Kingdom: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 24(4)-(6)
- United States: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 24(1)-(2), (6)
Data checked: 2026-11-10. A short summary for individuals; the full conditions, exceptions and protocols are in the treaty text. General information, not legal advice.