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HMRC internal manual

Employment Income Manual

Employer-financed retirement benefits schemes: overseas schemes

[Notice: the guidance on this page should be read with the notice at the top of EIM15015]

For this purpose, an overseas scheme is one where any of the income and gains of the scheme’s investments are or have been outside the charge to UK tax.

Receipts from employer-financed retirement benefits schemes are charged in full (see EIM15010) subject to transitional provisions (see EIM15125 and subsequent guidance).

Under the transitional provisions, the treatment of a lump sum paid after 5 April 2006 from such a scheme which existed as a funded unapproved retirement benefits scheme before 6 April 2006 depends on whether the scheme was both entered into before 1 December 1993 and has not been varied subsequently.

Note that where there is a charge, it may be eliminated by Extra-Statutory Concession A10 or Section 395B ITEPA 2003 (see EIM15082 onwards).