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HMRC internal manual

Business Income Manual

Specific deductions: pension schemes: S615 schemes

S393A Income Tax (Earnings and Pensions) Act 2003

A pension fund to which S615(3) Income and Corporation Taxes Act 1988 applies is not an employer-financed retirement benefits scheme.

These are pension funds set up for overseas employees, see TSEM5360 onwards for more detail. 

For employer contributions paid to S615 schemes before 6 April 2017, there were no special rules for the timing of relief, it followed the general accountancy principles explained at BIM31080 onwards.

From 6 April 2017 no further funds or rights to benefits can accrue under S615 schemes.  If an employer contribution is paid to the scheme on or after that date, the tax treatment follows that for a contribution to an employer-financed retirement benefits scheme (EFRBS) – see BIM46140.

If you need advice on cases where it is claimed that the fund is one to which S615 applies, contact IPD Technical (Pensions), see PTM011300.