Part 9U.K.Pension income

Chapter 4U.K.Foreign pensions: general rules

[F1576ATemporary non-residentsU.K.

(1)This section applies if a person is temporarily non-resident.

(2)Any relevant withdrawals within subsection (3) are to be treated for the purposes of section 575 as if they arose in the period of return.

(3)A relevant withdrawal is within this subsection if—

(a)it is paid to the person in the temporary period of non-residence, and

(b)ignoring this section, it is not chargeable to tax under this Part (or would not be if a DTR claim were made in respect of it).

(4)A “relevant withdrawal” is an amount paid under a relevant non-UK scheme that—

(a)is paid to the person in respect of a flexible drawdown arrangement relating to the person under the scheme, and

(b)would, if the scheme were a registered pension scheme, be “income withdrawal” or “dependants' income withdrawal” within the meaning of paragraphs 7 and 21 of Schedule 28 to FA 2004.

(5)If section 809B, 809D or 809E of ITA 2007 (remittance basis) applies to the person for the year of return, any relevant withdrawal within subsection (3) that was remitted to the United Kingdom in the temporary period of non-residence is to be treated as remitted to the United Kingdom in the period of return.

(6)This section does not apply to a relevant withdrawal if—

(a)it is paid to or in respect of a relieved member of the scheme and is not referable to the member's UK tax-relieved fund under the scheme, or

(b)it is paid to or in respect of a transfer member of the scheme and is not referable to the member's relevant transfer fund under the scheme.

(7)Nothing in any double taxation relief arrangements is to be read as preventing the person from being chargeable to income tax in respect of any relevant withdrawal treated by virtue of this section as arising in the period of return (or as preventing a charge to that tax from arising as a result).

(8)Part 4 of Schedule 45 to FA 2013 (statutory residence test: anti-avoidance) explains—

(a)when a person is to be regarded as “temporarily non-resident”, and

(b)what “the temporary period of non-residence” and “the period of return” mean.

(9)In this section—

(10)The following expressions have the meaning given in Schedule 34 to FA 2004—

Textual Amendments

F1S. 576A substituted (with effect in accordance with Sch. 45 para. 153(3) of the amending Act) by Finance Act 2013 (c. 29), Sch. 45 para. 116