 Lord Hoffman stated that Carson's case was typical of over 400,000 United Kingdom pensioners living abroad in countries which do not have reciprocal treaty arrangements under which annual cost of living increases are payable.Arrangements exist for countries within the European Economic Area (which is made up on European Union countries, Norway, Iceland and Lichtenstein) and a number of other countries such as the United States ("treaty countries").However, there are no such treaties with South Africa, Australia, New Zealand, Canada and many other countries.