This appeal concerns the proper interpretation and application of the UK-Portugal double tax convention (DTC). More specifically, whether withdrawals from the appellant’s self-invested personal pension (the TJM SIPP), paid to him while he was resident in Portugal and non-resident in the UK, are taxable in the UK or Portugal.

The appellant, Trevor Masters, was the former international CEO of Tesco and had spent over 30 years at the business, during which time he built up his pensions, before leaving in 2017.