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HMRC internal manual

International Exchange of Information Manual

Financial Accounts: Excluded Accounts: Retirement and Pension Accounts

Financial Accounts: Excluded Accounts: Retirement and Pension Accounts

All retirement accounts and products established under a:

  • UK registered pension scheme under Part 4 of the Finance Act 2004; and


  • Non-registered pension arrangement, including arrangements with overseas pension funds, where
    • Annual contributions are limited to £50,000; and
    • The funds contributed cannot be accessed before the age of 55, except in circumstances of serious ill health


  • Immediate needs annuity qualifying as such under Section 725 Income Tax (Trading and Other Income) Act 2005.


are in Annex II of the US and CDOT IGAs and are specifically listed as excluded accounts in Schedule 2 of the International Tax Compliance Regulations 2015. Consequently these are excluded accounts under all the regimes. Financial Institutions will have no reporting obligations in respect of these accounts or products. For clarification this applies to both the accumulation and decumulation phases of a pension scheme, contract or arrangement.

Registered Pension Scheme

A registered pension scheme is a pension scheme or contract that is registered with or deemed registered with HMRC. Any pension scheme or contract which had tax approval on 5 April 2006 (or whose tax approved status was granted on or after 6 April 2006, but was backdated so that the scheme was in effect approved on 5 April 2006) automatically became a registered pension scheme from 6 April 2006.

A deferred annuity “buy-out” contract which secures benefits which have arisen under a registered pension scheme is treated as a registered pension scheme from the date it is purchased.

Accumulation and Decumulation Phase

The accumulation phase is the accumulation of savings (or accrual of benefit) in a registered pension scheme or other pension arrangement.

The decumulation phase is the use of those accumulated funds to take a pension for the remainder of the individual’s or their dependant’s life.

“Pension” is defined under Section165 (2) Finance Act 2004, to include an annuity or income withdrawal as well as a pension that is paid directly from the pension scheme.


A trust based pension scheme purchases a Trustee Investment Plan (TIP) from a Reporting UK Insurance company. As the TIP is purchased by a Non-Reporting Financial Institution the Reporting UK Insurance Company is not required to review or report on the account.