PSI17.2.21 - Tax Treatment of Approved Schemes and Payments by Approved Schemes: Taxation of Payments to Scheme Members - Tax on Certain Commutation payments - Overseas Employment


(This archived guidance relates to HMRC discretionary practice before the 6th April 2006. For current guidance on Registered Pension Schemes see the Registered Pension Schemes Manual)

[PN17.29]

The section 599 charge does not apply where the employee’s employment was carried on outside the United Kingdom (section 599(4) ICTA 1988). We regard this condition as met where the employee is resident abroad provided sufficient of his or her service was carried out abroad to satisfy the conditions set out in PSI17.2.4. Alternatively, irrespective of the country of residence, the payment is treated as exempt if at least 75% of the employee’s service was carried out abroad. Service here means the service in respect of which the pension was granted.