Can I get both UK and Irish state pensions? Your complete guide

Following the UK's departure from the EU, a new Social Security Convention was put in place to protect the pension rights of people who have worked in both Ireland and the UK. If you've paid social insurance in both countries, the answer to 'can I get both UK and Irish state pensions?' is often yes, depending on your contribution history.

Quick Summary

Yes, you can potentially receive both a UK and an Irish state pension by leveraging bilateral social security agreements. Your contributions from each country are used to assess your eligibility and calculate a separate, pro-rata pension payment from each respective government.

Key Points

• Dual Entitlement: You can claim both UK and Irish state pensions if you have made sufficient contributions in each country, thanks to a bilateral social security agreement.

• Co-ordinated Process: Claims are co-ordinated by the social security authority in your country of residence, which communicates with its counterpart abroad.

• Pro-Rata Calculation: The amount you receive from each country is based on the proportion of contributions you paid into that country's system.

• Meeting Minimums: Contributions from one country can help you meet the minimum contribution requirements for a pension in the other.

• Voluntary Contributions: You may be able to pay voluntary contributions to fill gaps and increase your pension entitlement, but be mindful of deadlines.

• Tax Residency: Your dual pension will be taxable in the country where you are resident for tax purposes, though specific tax agreements may apply.

The Ireland-UK Social Security Convention

Since Brexit, the social security rights of individuals who have worked in both Ireland and the United Kingdom are protected by a specific bilateral agreement, the Convention on Social Security between Ireland and the United Kingdom. This convention ensures that your social insurance contributions (National Insurance in the UK and PRSI in Ireland) in one country are taken into account when applying for a state pension in the other. This prevents a person from losing out on pension benefits simply by having moved between the two jurisdictions.

How the Co-ordination System Works

Rather than transferring your contributions from one country to the other, the system works by coordinating your insurance history. When you apply for a state pension in your country of residence, that country's social security body will liaise with its counterpart in the other country. They will share your contribution records to determine if you meet the eligibility criteria for a pension from both. Each country then calculates and pays its own portion of the pension, based on the contributions made to its specific system.

Qualifying for an Irish State Pension (Contributory)

To qualify for the State Pension (Contributory) in Ireland, you generally need to be 66 or over and have a sufficient Pay Related Social Insurance (PRSI) record. The rules can be complex, especially with the transition from an averaging system to a total contributions system. The number of PRSI contributions required can vary, and your UK contributions may help you meet the minimum qualifying period, allowing for a pro-rata payment.

• Minimum Contributions: A minimum number of paid PRSI contributions are needed, which can be supplemented by crediting your UK National Insurance contributions.
• Annual Average: Under the old rules, your annual average of contributions was a major factor. This is being phased out in favour of a 'total contributions' approach, so it's important to understand which system applies to you, depending on your age and when you started working.

Qualifying for a UK State Pension

To be eligible for the new UK State Pension, you need at least 10 qualifying years of National Insurance (NI) contributions or credits. To receive the maximum amount, you need 35 qualifying years. If you don't have enough NI years, the UK's Department for Work and Pensions (DWP) will consider your Irish PRSI contributions to help you meet the 10-year minimum. This will result in a pro-rata UK pension based on the proportion of contributions made in the UK.

Making a Combined Pension Claim

When you are nearing state pension age, you should initiate your claim with the pension authority in the country where you are currently living. This authority will then handle the contact with their counterpart in the other country. For instance, if you are retiring in Ireland, you would apply through the Department of Social Protection, which would then coordinate with the UK's DWP. This simplifies the process and avoids you having to navigate two separate systems in parallel.

Key Steps in the Application Process

1. Check your record: Access your pension statement for both countries. You can do this online for the UK via the gov.uk website. For Ireland, you can request a statement from the Department of Social Protection.
2. Timing: Apply well in advance of your state pension age. It is recommended to start the process at least 6 months beforehand, as co-ordinating records can take time.
3. Provide all information: Ensure you provide full details of your employment history and social security numbers (NI number for the UK and PPS number for Ireland) for both jurisdictions. This helps expedite the process.

Potential Complications and Considerations

While the system is designed to be straightforward, there are nuances to be aware of.

Voluntary Contributions

If you have gaps in your contribution records in either country, you may be able to make voluntary contributions to increase your entitlement. For UK pensions, there are specific deadlines for buying back missed years, and rules regarding whether you can pay the cheaper Class 2 rate as a non-resident. It is essential to check the latest rules and deadlines, especially with recent changes.

Impact of Brexit

The Convention on Social Security between Ireland and the UK largely preserves the rights that existed under EU law for those with a cross-border working history. However, for future changes, it is important to stay updated with official government announcements from both countries. Your tax residency also plays a significant role in where you pay tax on your pension income.

Comparing UK and Irish Pensions

Feature	UK State Pension	Irish State Pension (Contributory)
Full Rate	Up to £221.20 per week (2024/25)	Up to €277.30 per week (2024)
Contribution Period	35 years for full pension	Varies, with transition to Total Contributions Approach
Minimum Years	10 qualifying years	Varies, with transition from average-based to total contribution-based
Combining Contributions	Co-ordinated via bilateral agreement	Co-ordinated via bilateral agreement
Age	Currently rising to 67	Currently 66, rising in future

Conclusion

In summary, it is absolutely possible to claim both UK and Irish state pensions, provided you have paid sufficient contributions in each country. Thanks to the bilateral Social Security Convention, your working history in one country will be considered by the other, ensuring you receive a pro-rata payment based on your record. The process is managed by the pension authority in your country of residence, who will coordinate with the other state on your behalf. By proactively checking your contribution history and applying on time, you can secure the pension income you are entitled to from both jurisdictions. For the most up-to-date and specific guidance, you should refer to official government sources like Citizens Information.

Frequently Asked Questions

How do UK and Irish authorities combine my records?

They don't combine them into one; instead, they coordinate. When you apply in your country of residence, that department requests a record of your contributions from the other country. Each country then calculates and pays a separate, pro-rata pension based on the contributions made to its own scheme.

What if I haven’t worked for the minimum 10 years in the UK?

Your Irish PRSI contributions can be used to help you meet the 10-year minimum for the UK State Pension. However, the amount you receive will be a pro-rata payment based on the actual number of years you contributed to the UK system.

Do I need to apply for each pension separately?

No, you should only need to apply through the pension authority in the country where you are retiring. That department will have a special form (like the CFN901 mentioned for the UK) and will then contact the other country on your behalf to process both claims.

How did Brexit affect the ability to get both pensions?

Following Brexit, the Convention on Social Security between Ireland and the UK replaced EU rules for co-ordinating pensions. This convention ensures that citizens who worked in both countries can continue to use their social insurance contributions from both to qualify for a pension, protecting existing rights.

Can I pay voluntary contributions to top up my pension?

Yes, both the UK and Ireland allow for voluntary contributions to fill gaps in your social insurance record. This is a common strategy for increasing your final state pension payment. It's crucial to check eligibility and deadlines, as these can change.

Will my UK pension be taxed in Ireland if I live there?

As a tax resident of Ireland, your worldwide income is generally taxable in Ireland. This includes your UK state pension. You must declare this income to the Irish tax authorities. There are tax agreements between the countries to prevent double taxation.

Is it possible to receive a full pension from both countries?

It is unlikely you will receive a full pension from both, as this would require paying the maximum number of contributions in both systems simultaneously, which is impossible. You receive a pro-rata portion from each, depending on your contribution history in each jurisdiction.