Moving to Argentina from the UK: what the 1996 convention does to a pension, and which way to read HMRC's table

For a British person moving to Argentina the immigration question is the one everyone asks first and the tax question is the one that costs money. The convention that settles the second has been in force since 1 August 1997, and most of what it does is not obvious from the summary tables published about it.

The short answer: under the 1996 UK–Argentina Double Taxation Convention, private pensions and annuities are taxable only in the state of residence (article 18(1)) — so once you are resident in Argentina, a UK private pension is not UK-taxable. Government service remuneration stays with the paying state, but article 19(1)(a) covers remuneration "other than a pension", and HMRC's own country summary lists government pensions under article 18 with the same treatment as other pensions. Employment income is taxable where the work is done unless presence in the other state does not exceed 183 days in a twelve-month period (article 15). Gains on immovable property may be taxed where the property is (article 13(1)). Withholding is capped at 10% or 15% on dividends, 12% on interest and 3%, 5%, 10% or 15% on royalties. And relief is asymmetric: the UK gives a credit, Argentina gives a deduction (article 23).

The dates that decide which rules applied when

From the official record: the convention was signed 3 January 1996, entered into force 1 August 1997, and took effect in the UK from 1 April 1998 for corporation tax and 6 April 1998 for income tax and capital gains tax, and in Argentina from 1 January 1998.

Those dates matter for one practical reason: the convention has been in force, unamended in the respects below, for the whole period any current mover will care about. The instrument is published by HMRC and is on our sources page.

Which state you are resident in, when both think you are

Article 4(1) defines a resident as a person liable to tax in a state by reason of domicile, residence or place of management. When both states would treat you as resident, article 4(2) runs a tie-breaker in a fixed order:

1. the state where you have a permanent home available to you;
2. if a home is available in both, the state with which your personal and economic relations are closer — the centre of vital interests;
3. if that cannot be determined, the state of your habitual abode;
4. if that is both or neither, the state of your nationality;
5. if that too is both or neither, the competent authorities decide by mutual agreement.

Note what is not in that list: your intentions, your visa category, and where your money is. Note also that nationality appears only at step four — which is why the UK–Argentina position differs from the US one described below.

A UK private pension becomes taxable only in Argentina

Article 18(1) covers "Pensions and other similar remuneration paid in consideration of past employment" and provides that they "shall be taxable only in that State" — the state of residence.

Read in the direction a leaver needs: once you are resident in Argentina for treaty purposes, your UK private pension is taxable only in Argentina, and the UK's taxing right over it goes. That is the single most consequential sentence in this convention for a retiree.

Government service pensions are not carved out. Article 19(1)(a) assigns government remuneration "other than a pension" to the paying state, with article 19(1)(b) reversing that where the services are rendered in the other state by a resident who is a national of it or who did not become resident solely to render the services. Pensions are excluded from that article by its own words, and HMRC's country summary for Argentina lists government pensions under article 18, with the same wording as other pensions. Most UK treaties keep a government-service pension taxable in the UK; on the face of these two sources, this one does not.

The direction trap in HMRC's own table, and how to read it

This is worth a section because getting it backwards reverses the answer.

HMRC publishes a country summary for Argentina in its Double Taxation Relief Manual. Its table lists, for each income type, what it calls the "treaty rate", and the manual states that this is "the maximum rate at which Argentina is permitted to tax income". In other words the table is written for income arising in Argentina and received by a UK resident — the inbound direction.

So where that table says pensions are "taxable only in the UK", it is telling a UK resident that Argentina may not tax their Argentine pension. It is not telling a person living in Argentina that the UK may tax their British pension. The convention's wording is reciprocal — "taxable only in that State", meaning the state of residence — and the outbound case is the mirror image.

A reader who finds the manual first and the treaty second can easily conclude the opposite of the truth. That is the kind of error this site exists to catch, and we point it out rather than quietly getting it right.

Employment income, and the 183 days

Article 15(1) makes employment income taxable in the state of residence unless the employment is exercised in the other state. Article 15(2) then returns the taxing right to the residence state where, cumulatively:

• presence in the other state does not exceed 183 days in aggregate in a twelve-month period;
• the employer is not a resident of that other state; and
• the cost is not borne by a permanent establishment or fixed base there.

For a UK employee working remotely from Argentina for a UK employer, those three conditions are the test to apply — and the day count is the one that is usually failed first.

Property, dividends, interest and royalties

• Immovable property gains — article 13(1): gains from disposing of immovable property situated in the other state may be taxed in that other state. So a UK property sold after the move remains within the UK's taxing right.
• Dividends — article 10(2): 10% where the beneficial owner is a company controlling, directly or indirectly, at least 25% of the voting power in the payer; 15% in all other cases.
• Interest — article 11(2): the source state's tax shall not exceed 12% of the gross amount. HMRC's summary adds a note of circumstances in which interest is taxable only in the recipient's state, among them interest paid by the Republic of Argentina itself.
• Royalties — article 12(2): 3% for news; 5% for copyright of literary, dramatic, musical or other artistic works; 10% for patents, trademarks, designs, secret formulas or processes, industrial or scientific equipment and technical assistance; 15% in all other cases.

A caveat HMRC states and we repeat: a treaty rate is a maximum, and the other conditions — beneficial ownership among them — still have to be met.

The relief methods are asymmetric, and that asymmetry is the trap

Article 23 does not do the same thing on both sides:

• The UK gives relief by credit: Argentine tax on income from Argentine sources is allowed as a credit against UK tax computed on the same income (article 23(1)(a)).
• Argentina gives relief by deduction: it allows a deduction from the tax on a resident's income of an amount equal to the income tax paid in the United Kingdom (article 23(2)(1)(a)), with the equivalent for capital tax in (b).

Our reading, labelled as a reading: the two mechanisms are not always equivalent in outcome, and which one applies to you depends on which state you are resident in — which is itself decided by article 4 rather than by choice. We are not going to compute an example, because the result depends on rates and timing we cannot see; what this page does is tell you that the asymmetry exists, which is the part the summaries omit.

What this convention does not contain

It contains no provision we could find allowing a state to tax its nationals regardless of residence. Nationality enters article 4 only at the fourth step of the tie-breaker.

That is the sharp difference from the American position. A US citizen moving abroad stays within the US tax net because of the saving clause in the US treaties, which is the subject of moving to Portugal from the US. A British citizen moving to Argentina does not carry an equivalent clause with them.

The limit on that statement: we read the convention through HMRC's official publication page and its Double Taxation Relief Manual on 9 November 2026. The full PDF of the convention did not retrieve when we tried it, so this is an absence in the text we read rather than a verified absence from every article of the instrument, and the page says so rather than claiming more.

The immigration side, and where it is covered

This page is the tax half. The Argentine residence routes themselves — and what the courts have done to the two-year citizenship claim — are elsewhere on this site:

• The rentista and pensionado routes: retiring in Argentina.
• The digital nomad route: the Argentine digital nomad visa.
• Citizenship, including what is and is not established about the two-year route: Argentine citizenship.
• Buying rural land, where the 2011 limits were repealed and a court suspended the repeal: buying land in Argentina.

Frequently asked questions about moving to Argentina from the UK

More on Argentina and on moving from the UK

The residence routes, the retirement options and the citizenship position are in retiring in Argentina, the digital nomad visa and Argentine citizenship. Rural land, where the limits were repealed and the repeal suspended, is in buying land in Argentina. The same treaty question for a different destination, where a new convention replaced the 1968 one in 2025, is in moving to Portugal from the UK. The American contrast, where the saving clause changes everything, is in moving to Portugal from the US. The instruments named here, with the date we read them, are on the sources page.