Background International
28.There are circumstances in which an overseas pension scheme that is not a registered pension scheme will contain funds that have benefitted from UK tax relief. For example, where an individual comes to the UK as a member of an overseas pension scheme, contributions to their overseas scheme may benefit from UK tax relief just like contributions to a registered pension scheme. Funds in an overseas pension scheme which have built up in a registered pension scheme before being transferred to the overseas pension scheme will also have benefited from UK tax relief.
29.Finance Act 2004 therefore contains charging provisions which apply in certain circumstances to members of non-UK pension schemes which are intended to reflect similar charges that would have applied had those funds been held in a registered pension scheme. However, for members of non-UK pension schemes, these charges only relate to the part of the member's non-UK pension fund that has benefitted from UK tax relief.