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HMRC internal manual

Employment Income Manual

The taxation of pension income: Pensions taken as flexible drawdown: temporary non-residence: persons within the scope of section 576A: persons not domiciled or not ordinarily resident in the UK: remittance basis

When a person who meets all the four conditions in section 576A(2) ITEPA 2003 returns to the UK and is resident for tax purposes, they are normally liable to a pension income tax charge in respect of any flexible drawdown paid from an overseas pension scheme during the period of temporary non-residence (see EIM74055).

But where:

  • the person is either not domiciled or not ordinarily resident in the UK in the year of return, and
  • the remittance basis, see SAIM1130, applies to that person for the year of return

the charge is limited to amounts of flexible drawdown paid from a relevant non-UK scheme (see RPSM13102130 for more detail) which were remitted to the UK in a year of non-residence. The remitted amounts are treated as remitted in the year of return.