On 15 May 2008 Anneli transfers £200,000 from a relevant
non–UK scheme (scheme B) to another relevant non-UK scheme
(scheme C) which is a qualifying recognised overseas pension scheme
and also an investment–regulated pension scheme. Included in
the amount transferred is a UK tax-relieved fund of £50,000
and a relevant transfer fund of £100,000. Her relevant
transfer fund under scheme B is wholly made up of an amount
transferred from a registered pension scheme (scheme A) so her
taxable asset transfer fund under scheme B amounted to
£100,000.
Anneli has a relevant transfer fund of £150,000 under
scheme C, of which £100,000 is represented by her taxable
asset transfer fund. She does not have a UK tax-relieved fund under
scheme C.
On 28 May 2008 scheme C buys a taxable property for
£200,000 which is held under Anneli’s arrangement. That
is an unauthorised deemed payment and is treated as made partly out
of her relevant transfer fund and her taxable asset transfer fund.
It gives rise to a member payment charge (and surcharge) on
£100,000 - the part of the purchase price referable to her
taxable asset transfer fund. That £100,000 interest in the
appropriated asset is treated as going into Anneli’s relevant
transfer fund and her taxable asset transfer fund.
On 9 December 2009 scheme C sells the taxable property for
£250,000. £100,000 of those proceeds are treated as
forming part of Anneli’s relevant transfer fund and taxable
asset transfer fund under scheme C. So her relevant transfer fund
remains at £150,000 and her taxable asset transfer fund
remains at £100,000.
On 1 October 2010 Anneli receives a lump sum payment of
£50,000 from scheme C. That is treated as made out of her
relevant transfer fund but not her taxable asset transfer fund. It
gives rise to an unauthorised payment charge. Her relevant transfer
fund is reduced to £100,000 and becomes made up wholly of her
taxable asset transfer fund.
On 29 July 2012 scheme C uses the remaining £250,000 in
Anneli’s arrangement to provide her with a pension. The first
£100,000 is treated as made out of her relevant transfer fund
and taxable asset transfer fund, but no unauthorised payment charge
arises as it is not an unauthorised payment.
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| Glossary ( RPSM20000000) |
