Pension Lump Sums and Treaty Relief

Pension Lump Sums and Treaty Relief

The interaction between pension lump sums and relief under a treaty had long been a subject of discussion at the now disbanded Expat Forum. Forum members gave their time and expertise over a number of years to help HMRC with this difficult topic. HMRC repeatedly promised to publish guidance and repeated failed to do so.

I was, therefore, shocked to discover that finally after years of delay the guidance was published on 12 March 2025 with little fanfare and can now be found as a page in the international manual at: INTM163160 - Pensions - Lump Sums - HMRC internal manual - GOV.UK.

Although, I am pleased that finally the guidance has been published, it is disappointing, that HMRC did not recognise the work put in by members and did not have the courtesy to inform them that they had published the guidance. No doubt HMRC are embarrassed by how long it took them.

Will we now get the other outstanding issues resolved?

Lee McIntyre-Hamilton

Tax Partner at Keystone Law (Global Mobility and Employment Tax)

3 天前

Well done Steve and the Expat Forum team involved. Thanks for sharing. Of course, having clarity on matters such as this is vital and saves everyone (not least, HMRC) so much otherwise wasted time. Like many, I have clients who have been waiting for clarity on this for several years. The disbandment of the Expat Forum by HMRC is clearly a false economy and very disappointing that HMRC couldn't bring themselves to feed back via the former forum members.

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