Totalization Agreement with United Kingdom | International Programs (2024)

Totalization Agreement with United Kingdom

Contents

Introduction
Eliminating dual coverage for self-employment
United Kingdom certificates for employees and self-employed workers
Monthly benefits
How benefits can be paid
Claims for benefits
Payment of benefits
For more information about United Kingdom's social security programs

Introduction

For United Kingdom, the Agreement covers old-age, survivors, disability benefits, cash sickness benefits, maternity benefits, death grants, unemployment insurance, and benefits under the Industrial Injuries Scheme.

Note: U.K. disability benefits, including Universal Credit, Personal Independence Payment, Employment and Support Allowance (ESA), require residence in the U.K. ESA replaced the Incapacity Benefit and Income Support effective October 27, 2008. Individuals who received Incapacity Benefit and Income Support prior to October 27, 2008, will continue to receive these benefits as long as they continue to satisfy the entitlement conditions. The Industrial Injuries Disabled Benefit payments require that the work accident or event that caused a worker’s illness occurred in England, Scotland or Wales.

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Eliminating dual coverage for self-employment

  • Self-employed workers who reside in the United States are assigned U.S. coverage.
  • Self-employed workers who reside in the United Kingdom are assigned U.K. coverage.

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United Kingdom certificates for employees and self-employed workers

Employers and self-employed workers must request a certificate of coverage to establish an exemption from U.S. Social Security contributions.

Applications can be made online by visiting this link: Check how to apply for a certificate - GOV.UK (www.tax.service.gov.uk)

Please mail your request to:

HM Revenue & Customs
PT Operations North East England
BX9 1AN
United Kingdom

Please provide the following information:

  • Worker's full name (including maiden name);
  • Worker's date of birth;
  • Worker's place of birth;
  • Worker's country of citizenship;
  • Worker's country of permanent residence;
  • Worker’s U.S. social security number;
  • Worker's U.K. social security number, if applicable;
  • Date of hire, if employed;
  • Country of hire, if employed;
  • Nature of self-employment activity, if applicable;
  • Name and address of the employer in the United States and the Agreement country (if self-employed, address of trade or business in both countries); and
  • Date of transfer and anticipated date of return of employment or self-employment in the Agreement country.

In addition, your employer must indicate if you remain an employee of the U.S. company while working in the United Kingdom or if you become an employee of the U.S. company’s affiliate in the United Kingdom.

U.S. employers should retain certificates of coverage in case of an audit by the IRS. Employers should not send a copy to the IRS unless the IRS specifically requests the certificate of coverage.

Self-employed workers should attach a copy of the certificate of coverage to their U.S. tax return every year as proof of the exemption.

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Monthly benefits

Under the U.S. Social Security system, you may earn up to four credits each year depending on the amount of your covered earnings. For example, in 2022, you receive one credit for each $1,410 of your covered annual earnings up to a maximum of four credits per year. For more information, see How You Earn Credits (Publication No. 05-10072).

Under the U.K. system, credits are measured in weeks. To simplify the information in the table, requirements are shown in years of credits.

Retirement or old-age benefits

United States

United Kingdom

Worker—Full benefit at full retirement age.* Reduced benefit as early as age 62. Required work credits range from one and one-half to 10 years (10 years if age 62 in 1991 or later).

Worker—Full benefit at age 65 for men with 44 years of contributions, or reduced benefit with 11 years. Full benefit at age 60 for women (increasing to age 65 between 2010 and 2020) with 40 years of contributions, or reduced benefit with 10 years.

*Full retirement age is 66 for people born in 1943-1954 and will gradually increase to age 67 for people born in 1960 or later.

Disability benefits

United States

United Kingdom

Worker—Under full retirement age* can get benefit if unable to do any substantial gainful work for at least a year. One and one-half to 10 years credit needed, depending on age at date of onset. Some recent work credits also needed unless worker is blind.

Worker—A contributor who has not retired can get an invalidity benefit if the contributor has been incapable of working for 52 weeks during which time the contributor was entitled to statutory sickness pay or short-term incapacity benefits. The contributor must have paid a required number of contributions in a recent tax year.

*Full retirement age is 66 for people born in 1943-1954 and will gradually increase to age 67 for people born in 1960 or later.

Family benefits to dependents of retired or disabled people

United States

United Kingdom

Spouse—Full benefit at full retirement age* or at any age if caring for the worker’s entitled child under age 16 (or disabled before age 22). Reduced benefit as early as age 62 if not caring for a child.

Wife—Retirement pension at age 60 based on spouse’s contributions if the wife does not qualify for a higher pension based on their own contributions. If under age 60, an increased pension is paid to the spouse. An increased invalidity benefit is payable for a spouse in certain circ*mstances.

Husband—Husband cannot claim extra retirement pension for spouse, but can claim increased invalidity benefit in certain circ*mstances.

Divorced spouse—Full benefit at full retirement age.* Reduced benefit as early as age 62. Must be unmarried and have been married to worker for at least 10 years.

Divorced Wife— Retirement pension payable at age 60 based on ex-spouse’s contributions provided the divorced wife has also contributed to the U.K. system. Remarriage after age 60 will not affect entitlement.

Divorced spouse— Same as divorced spouse.

Divorced Husband— At age 65; other requirements same as divorced wife.

ChildrenIf unmarried, up to age 18 (age 19 if in an elementary or secondary school full time) or any age if disabled before age 22.

Children—Up to age 16 (age 19 for certain students).]

*Full retirement age is 66 for people born in 1943-1954 and will gradually increase to age 67 for people born in 1960 or later.

Survivors benefits

United States

United Kingdom

Surviving Spouse—Full benefit at full retirement age* or at any age if caring for the deceased’s entitled child under age 16 (or disabled before age 22). Reduced benefit as early as age 60 (or age 50 if disabled) if not caring for a child. Benefits may be continued if remarriage occurs after age 60 (or age 50 if disabled).

Widow—Full benefit at age 55 or at any age if caring for a dependent child of the worker. Reduced benefit as early as age 45. Benefit may continue if remarriage occurs after age 60.

Widower—Benefit payable at age 65, if widowed before age 65 and also contributed to the U.K. system.

Divorced Surviving Spouse— Same as surviving spouse if marriage lasted at least 10 years.

Divorced Surviving Spouse—No provision.

Children—Same as for children of retired or disabled worker..

Children—Same as for children of retired or disabled contributors.

Lump-sum death benefit—A one-time payment not to exceed $255 payable on the death of an insured worker. Lump-sum death benefit—No provision.

*Full retirement age is 66 for people born in 1943-1954 and will gradually increase to age 67 for people born in 1960 or later.

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How benefits can be paid

If you have social security credits in both the United States and the United Kingdom, you may be eligible for benefits from one or both countries. If you meet all the basic requirements under one country’s system, you will get a regular benefit from that country. If you do not meet the basic requirements, the Agreement may help you qualify for a benefit as explained below.

  • Benefits from the United States - If you do not have enough work credits under the U.S. system to qualify for regular benefits, you may be able to qualify for a partial benefit from the United States based on both United States and United Kingdom credits. However, to be eligible to have your U.K. credits counted, you must have earned at least six credits (generally one and one-half years of work) under the U.S. system. If you already have enough credits under the U.S. system to qualify for a benefit, the United States cannot count your U.K. credits.
  • Benefits from the United Kingdom - The United Kingdom provides benefits through a two-tier program:
  1. The first tier, called the basic pension, is payable to workers who meet a minimum length of work requirement. Under the Agreement, if you do not have enough credits under the U.K. system, your U.S. credits can be counted. To be eligible to have your United States and United Kingdom credits counted, you must have at least one year of coverage credited under the U.K. system.
  2. The second tier is called the additional pension and is based on both the length of work under the U.K. system and the amount of earnings. A person can qualify for the additional pension with as little as one year of U.K. coverage. Therefore, credits under the U.S. system will not be considered when determining eligibility for the additional pension.

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Claims for benefits

If you live in the United States and wish to apply for United States or United Kingdom benefits:

  • Visit or write any U.S. Social Security office.
  • Phone our toll-free number, 1-800-772-1213, 8 a.m. to 7 p.m. any business day. People who are deaf or hard of hearing may call our toll-free TTY number, 1-800-325-0778.
  • You can apply for U.K. benefits at any U.S. Social Security office by completing an application form SSA-2490-BK (Application for Benefits Under a U.S. International Social Security Agreement).

If you live in the United Kingdom and wish to apply for United States or United Kingdom benefits, contact:

  • The Federal Benefits Unit at the U.S. Embassy in London (phone 207-499-9000) to file for U.S. benefits.
  • Any U.K. social security office to file for U.K. benefits.

If you live outside the United States and wish to apply for benefits, contact:

Federal Benefits Unit
United States Embassy
33 Nine Elms Lane
LONDON
SW11 7US

You can apply with one country and ask to have your application considered as a claim for benefits from the other country. Each country will process the claim under its own laws, counting credits from the other country when appropriate, and notify you of its decision.

If you have not applied for benefits before, you may need to provide certain information and documents when you apply.

These may include:

  • Worker’s United States Social Security number.
  • Worker’s United Kingdom social security number.
  • Worker’s proof of age for all claimants.
  • Evidence of the worker’s U.S. earnings in the past 24 months.
  • Information about the worker’s coverage under the United Kingdom system.

You may wish to call the social security office before you go there to see if you need any other information.

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Payment of benefits

Each country pays its own benefit. U.S. payments are made by the U.S. Department of Treasury each month and cover benefits for the preceding month. Payments under the U.K. system may be paid at different times and for various periods of time depending upon the amount of the payment and the wishes of the recipient. For more information, contact the United Kingdom authorities at the address in the section titled, “For more information.”

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For more information about United Kingdom's social security programs

If you live in the United Kingdom, contact your nearest office of the Department for Work and Pensions, or visit the United Kingdom’s Department for Work & Pensions website at Department for Work and Pensions - GOV.UK (www.gov.uk).

If you live outside the United Kingdom, and want information about benefits, contact:

Department for Work and Pensions
Pensions and Overseas Directorate
Tyneview Park
Whitley Road Benton
NE98 1BA
ENGLAND

If you live in the UK but work abroad and require further information about your National Insurance obligations, please visit this link National Insurance if you work abroad - GOV.UK (www.gov.uk) or write to:

HM Revenue & Customs
PT Operations North East England
BX9 1AN
United Kingdom

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Totalization Agreement with United Kingdom | International Programs (2024)

FAQs

What is the totalization agreement between the US and the UK? ›

Totalization Agreement

The agreement between the two nations allows these individuals to still obtain a benefit. In this case, the US and UK benefits will each pay out pro-rata based on the time spent working (i.e. accruing credits) in each jurisdiction.

How does a totalization agreement work? ›

Totalization Agreements, also referred to as bilateral agreements, eliminate dual social security coverage (the situation that occurs when a person from one country works in another country and is required to pay social security taxes to both countries on the same earnings).

Does UK state pension affect US social security? ›

Windfall Elimination Provision (WEP)

WEP is a feature of Social Security that can lead to benefits being reduced to reflect a “eligibility for a pension from work not covered by Social Security” – i.e. the UK State Pension.

What countries does the US have totalization agreements with? ›

Agreement Descriptions
  • Australia. Austria. Belgium. Brazil. Canada. Chile.
  • Czech Republic. Denmark. Finland. France. Germany. Greece.
  • Hungary. Iceland. Ireland. Italy. Japan. Luxembourg.
  • Netherlands. Norway. Poland. Portugal. Slovak Republic. Slovenia.
  • South Korea. Spain. Sweden. Switzerland. United Kingdom. Uruguay.

Can you live abroad and collect social security disability? ›

If you are a U.S. citizen, you may receive your Social Security payments outside the U.S. as long as you are eligible for them. However, there are certain countries to which we are not allowed to send payments.

Can you collect social security with dual citizenship? ›

The United States generally considers a person with dual U.S. and foreign citizenship a U.S. citizen for Social Security purposes. This does not apply if you are a U.S. citizen and a citizen of a country the United States has an international social security agreement with.

How does foreign income affect social security? ›

If you are among the growing number of Americans who spend part of their career working outside the United States, both the United States and a foreign social security system cover your work. You would normally have to pay social security taxes to both countries for the same work.

What is the minimal social security payment? ›

The Social Security special minimum benefit provides a primary insurance amount (PIA) to low-earning workers. The lowest minimum PIA, with at least 11 years of work, is $49.40 per month in 2023 and $50.90 in 2024.

What countries do not tax US social security benefits? ›

You're ready to embrace the expat life with confidence.
  • Panama. Panama tops most lists of the best countries to retire in, and there are good reasons for that. ...
  • Costa Rica. ...
  • Portugal. ...
  • Ecuador. ...
  • Greece. ...
  • Belize. ...
  • Nicaragua. ...
  • The Philippines.

What happens to my UK State Pension if I move to USA? ›

As long as you qualify for the UK State Pension, you'll still receive it even if you move abroad when you retire – and you can still access any workplace or private pensions you have. If you're an EU national who's built up a pension in the UK, you'll still be able to access it or move it to the country of your choice.

Can I draw my UK State Pension in USA? ›

You can claim State Pension abroad if you've paid enough UK National Insurance contributions to qualify. Get a State Pension forecast if you need to find out how much State Pension you may get.

Can I get my UK pension paid in the USA? ›

You can claim and receive a UK State Pension while living overseas. But Pension Credit stops when you move overseas permanently. This is a means-tested benefit, which can top up your weekly income. Your State Pension can be paid to a UK bank or building society account, or to an overseas account in the local currency.

Can I claim both UK and US social security? ›

How benefits can be paid. If you have social security credits in both the United States and the United Kingdom, you may be eligible for benefits from one or both countries. If you meet all the basic requirements under one country's system, you will get a regular benefit from that country.

What does a totalization agreement allow? ›

Employees working in the U.S. and abroad often find that they have not worked long enough in any jurisdiction to meet eligibility requirements. The totalization agreements allow such workers to qualify for benefits based on combined coverage credits from multiple countries.

Is UK social security taxable in the US? ›

Hi, Article 17(3) of the UK/USA Double Taxation Treaty stipulates that payments made by one of the Contracting States under the provisions of its social security or similar legislation to a resident of the other Contracting State will be taxable only in the other Contracting State.

What is the treaty between the US and the UK? ›

The U.S./U.K. tax treaty—formally known as the “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” ...

What is the pact between the US and the UK? ›

The US–UK Mutual Defense Agreement, or the 1958 UK–US Mutual Defence Agreement, is a bilateral treaty between the United States and the United Kingdom on nuclear weapons co-operation.

What is the UK-US Adequacy Agreement? ›

Overview. The UK government has published the Data Protection (Adequacy) (United States of America) Regulations 2023 (SI 2023/1028) (the UK-US Data Bridge Regulations) which adopted an adequacy decision for the US (the UK-US Data Bridge) and will come into force on 12 October 2023.

Is there a trade agreement between UK and US? ›

In June 2023, Biden and Sunak announced the 'Atlantic Declaration' to strengthen economic ties between the UK and the US. The agreement included a limited trade pact covering critical minerals needed for EV batteries, a new data protection deal, and easing other trade barriers.

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