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HMRC internal manual

Trusts, Settlements and Estates Manual

Trusts for particular purposes: employment-related trusts: retirement benefits: ICTA88/S615 schemes - introduction

Where an unapproved retirement benefits scheme meets certain requirements in S615 ICTA 1988:

  • the trust is exempt to an extent from income tax and capital gains tax
  • the trustees may pay annuities free of tax
  • employees may receive sums tax free

but income arising in the UK to UK resident trustees remains taxable.

No new S615 schemes can be established after 5 April 2017. If an existing scheme receives contributions from 6 April 2017, that part of the fund will not be treated as having S615 status.

Whether a scheme meets S615 conditions should be considered by Pension Scheme Services.

Such trusts will be dealt with by HMRC Trusts Nottingham under normal SA procedures.