INTM162129 - UK residents with foreign income or gains: certificates of residence: for UK registered pension schemes: Pension Protection Fund (PPF)

The PPF is a fund held, managed and applied by the Board of the Pension Protection Fund (BPPF). The BPPF is a body corporate and is treated in the same way as registered pension schemes for UK tax purposes, with certain exceptions.

Unless the double taxation agreement specifically includes pension schemes within its definition of a resident (in which case it may be possible to issue a certificate of residence in the name of the PPF), a certificate of residence will normally be issued using the following form of words:

“I certify that to the best of HM Revenue & Customs’ knowledge, the Board of the Pension Protection Fund, as the holder and manager of the Pension Protection Fund, is, as at [date], a resident of the UK in accordance with Article [number applicable to residence - usually 4] of the Convention in force between the UK and [name of other state].”