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HMRC internal manual

Employment Income Manual

HM Revenue & Customs
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Employer-financed retirement benefits schemes: Extra-Statutory Concession A10: aim

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

EFRBS charges might not apply where benefits have accrued in relation to ‘foreign service’.  Such ‘foreign service’ relief originally operated as a concession under ESC A10 and later under legislation at Section 395B ITEPA 2003.

The ‘foreign service’ relief for EFRBS applies to lump sum relevant benefits (defined at EIM15021). This includes both lump sums received under the rules of an overseas EFRBS and lump sums received in commutation of pension rights under such a scheme. The tax treatment of pension commutation payments is dealt with at EIM15150.

Note: this ‘foreign service’ relief does not apply to benefits from EFRBS provided in the form of a pension or annuity; these remain chargeable as pension income.

The guidance at EIM15083 presents this ‘foreign service’ relief in its original form as ESC A10. Subsequent pages provide further details, including later legislation.