Special pensions

WHO pensioners in Denmark
31March 2005 is the deadline for WHO pensioners
residing in Denmark to inform the
tax authorities if they want to switch to taxation
under the law on taxation, or about their choice
of how their income should be taxed. If they do it
by this deadline, the new regulations for tax
exemptions will be applied to their case for one
year retroactively, i.e. from 01.01.2004. The new
regulation has finally put all Denmark-based UN
pensioners in a position of equality, no matter
when they joined the UN Joint Pension Fund
(before or after February 1992).
What's new?
On 17 December 2004, the Danish parliament
finished its third reading of the proposed
amendments of the Danish law which regulates
taxation of certain foreign pensions (law
No 429/ 26.061998). According to this amendment,
all current and future pensioners of
WHO and, for that matter, of any UN agency,
who choose to reside in Denmark and who
joined the Pension Fund prior to February
1992, will be now taxed equally, regardless of
their date of entry into the UN Pension Fund.
In practical terms this means that each such
pensioner will have the opportunity to choose
to be taxed on the accrued annual interest of
their «capital» in the Pension Fund.
What’s old?
Before the amendment came into force a month
ago, there was inequity between two groups of
former WHO staff – the ones who had joined the
UN Joint Pension Fund before or after February
1992. The first group was taxed on their monthly income (their pensions), while the second group
was taxed only on the interest of the pension
paid out each year.
How did it go?
The process for ensuring equity for pensioners
was formally started in spring 2004 when WHO
administration approached the Danish Ministry
of Taxation, speaking out for all WHO staff’s
right to be treated equally by the hosting country.
Although this was originally initiated in the interest
of WHO pensioners, the case was applicable
for all UN staff. The text of the amendments was
drafted by the Ministry of Taxation and submitted
to the Danish Parliament in summer 2004.
Within few months, there was a very speedy
process of going through all the formal parliamentary
proceedings for receiving technical
comments and for three consequent readings,
and the amendment was put into force. Overall,
though, this amendment only removes a timeconstraint
«Rubicon» in the law on taxation of
foreign pensioners which does not refer specifically to UN pensioners and has not been introduced
by the Danish state concretely for the benefit
of present and future UN pensioners.
What’s on now?
WHO is pursuing its discussions with the tax
authorities on the last pending point i.e. the taxation
of interest, and options are being negotiated.
An agreement with the tax authorities on how
and to which extent the capital interest should
be taxed is foreseen shortly. As soon as such an
agreement has been reached, a briefing will be
held to inform staff about the outcome.
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