PTM175360 - Lump sum allowance and lump sum and death benefit allowance: Non-residence: Notification

As of 6 April 2024 there is no longer lifetime allowance. If you are looking for information about protections, enhancement factors and the lifetime allowance charge please see these pages on The National Archives. If you are looking for information about the principles of lifetime allowance and benefit crystallisation events please see these pages of The National Archives.

If you are looking for information about enhancement factors pre-April 2024 please see The National Archive.  The below guidance applies for individual’s seeking an enhancement factor from 6 April 2024 to 5 April 2025.

Notification procedure

APSS 202

When separate notifications of a non-residence factor are needed

Notification procedure

Regulations 7 and 12 The Registered Pension Schemes (Enhanced Allowances) Regulations 2006

An individual must notify HMRC of their entitlement to a non-residence allowance enhancement factor.

Notification should be made on form APSS 202 and should be made on the earlier date of:

  • no later than five years after 31 January following the end of the tax year in which the accrual period ended, or
  • 5 April 2025

After 5 April 2025 an individual will be unable to rely upon non-residence enhancement factors.

The accrual period ends when the earliest of the following events occurs:

  • Immediately before a benefit payment,
  • The individual ceases to be a relevant overseas individual,
  • Benefits cease to accrue to or in respect of the individual under the arrangement, and
  • 5 April 2024.

APSS 202

The form APSS should be used to notify HMRC of an entitlement to a non-residence factor for part of an active membership period relating to a pension arrangement during which the individual as a relevant overseas individual.

Separate APSS 202 notification forms should be submitted to HMRC in certain circumstances.

A single APSS 202 form can be submitted where an individual has been accruing benefits under different types of arrangement within a single registered pension scheme that has multiple arrangements. Such an individual can notify HMRC of a non-residence factor relating to all of their arrangements under the scheme. They will need to fill in all of the sections of the form that apply to those arrangements.

Special consideration needs to be given to an individual who is a member of a hybrid arrangement.

Example of notifying HMRC to entitlement to a non-residence factor

Phillip returned from an overseas secondment with an overseas resident employer on 1 June 2018. He was a relevant UK individual in the 2018-2019 tax year so he ceased to be a relevant overseas individual with effect from 5 April 2018. At that time he was still accruing benefits under the arrangement and had not been paid benefits from it.

To claim an enhancement Phillip must submit a completed form APSS 202 to HMRC no later than five years after 31 January 2019, i.e by 31 January 2024

When separate notifications of a non-residence factor are needed 

Separate APSS 202 notification forms should be submitted to HMRC in the following circumstances.

Relevant overseas individual during more than one part of an active membership period

Where an individual is a relevant overseas individual during more than one part of an active membership period relating to the same pension arrangement a separate notification should be made for each part-period.

Relevant overseas individual in more than one pension scheme

Where an individual is a relevant overseas individual during part of an active membership period relating to more than one pension scheme a separate notification should be made for each pension scheme.

Relevant benefit crystallisation event occurs in an arrangement whilst the individual is a relevant overseas individual and is still accruing benefits under the arrangement

One APSS 202 form should relate to the part of the active membership period during which the individual was a relevant overseas individual up to the date of that relevant benefit crystallisation event. Another APSS 202 form should relate to the part-period from the same start date to the date of the following relevant benefit crystallisation event. The individual should tick box 1.6 on the second form, to show that it is amending the first notification, and should enter on that form the reference number shown on the certificate issued in response to the first notification. Any figures entered at box 4.1 or box 6.1 on the second form should be calculated by adding the rights or benefit entitlement used up on the first relevant benefit crystallisation event to the rights or benefit entitlement as at the date of the second relevant benefit crystallisation event.

However, if the second relevant benefit crystallisation event occurs before the end of the notification time limit relating to the first relevant benefit crystallisation event, and before the individual has submitted a form APSS 202 in respect of the part-period up to the date of the first benefit crystallisation event, the individual can submit one form instead of two. That form should relate to the same part-period as would be covered by the second form referred to above. Any figures entered at box 4.1 or box 6.1 on the form should be calculated by adding the rights or benefit entitlement used up on the first relevant benefit crystallisation event to the rights or benefit entitlement as at the date of the second relevant benefit crystallisation event. Box 1.6 should not be ticked as this form is not amending an earlier notification. The form must be submitted within the notification time limit relating to the first relevant benefit crystallisation event.