(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)
An overseas scheme which is wholly or partly approved under
Chapter I Part XIV ICTA 1988 is generally for United Kingdom based
employees. A pensioner who retires abroad will not therefore
qualify for exemption from United Kingdom tax under the overseas
service test in
PSI17.2.4. The only reliefs available
are normally under a Double Taxation Agreement if one exists or
under section 278 ICTA 1988 (see
PSI17.2.5).
(This text has been withheld because of exemptions in the
Freedom of Information Act 2000)
The scheme rules must therefore require the pensions to be
purchased in accordance with
PSI17.2.6. This applies also to any
rules which enable individual annuities to be bought, for example,
when the scheme is wound-up or the employee leaves service. Refer
any objection to this requirement to your Divisional Manager.