615 Exemption from tax in respect of certain pensions

615  Exemption from tax in respect of certain pensions

(1)     . . .

(2)     . . .

(3)     Where an annuity is paid from a superannuation fund to which this subsection applies to a person who is not resident in the United Kingdom, income tax shall not be deducted from any payment of the annuity or accounted for under [Chapter 6 of Part 15 of ITA 2007 (deduction from annual payments and patent royalties)] by the trustees or other persons having the control of the fund.

(4)     . . .

(5)     . . .

(6)     Subsection (3) above applies to any superannuation fund which—

(a)     is bona fide established under irrevocable trusts in connection with some trade or undertaking carried on wholly or partly outside the United Kingdom;

(b)     has for its sole purpose [(subject to any enactment or Northern Ireland legislation requiring or allowing provision for the value of any rights to be transferred between schemes or between members of the same scheme)] the provision of superannuation benefits in respect of persons' employment in the trade or undertaking wholly outside the United Kingdom; . . .

(c)     is recognised by the employer and employed persons in the trade or undertaking; [and

(d)     meets the benefit accrual condition (see subsection (6A));]

and

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