PTM175360 - Lump sum allowance and lump sum and death benefit allowance: Non-residence: Notification
As of 6 April 2024 there is no longer lifetime allowance. If you are looking for information about protections, enhancement factors and the lifetime allowance charge please see these pages on The National Archives. If you are looking for information about the principles of lifetime allowance and benefit crystallisation events please see these pages of The National Archives.
If you are looking for information about enhancement factors pre-April 2024 please see The National Archive. The below guidance applies for individual’s seeking an enhancement factor from 6 April 2024 to 5 April 2025.
When separate notifications of a non-residence factor are needed
Regulations
7 and 12 The Registered Pension Schemes (Enhanced Allowances) Regulations 2006
An individual must notify HMRC of their entitlement to a non-residence
allowance enhancement factor.
Notification should be made on form APSS 202 and should be made on the earlier
date of:
- no later than five years after 31 January following the end of the tax year in which the accrual period ended, or
- 5 April 2025
After 5
April 2025 an individual will be unable to rely upon non-residence enhancement
factors.
The accrual period ends when the earliest of the following events occurs:
- Immediately before a benefit payment,
- The individual ceases to be a relevant overseas individual,
- Benefits cease to accrue to or in respect of the individual under the arrangement, and
- 5 April 2024.
The form
APSS should be used to notify HMRC of an entitlement to a non-residence factor
for part of an active membership period relating to a pension arrangement
during which the individual as a relevant overseas individual.
Separate APSS 202 notification forms should be submitted to HMRC in certain
circumstances.
A single APSS 202 form can be submitted where an individual has been accruing
benefits under different types of arrangement within a single registered
pension scheme that has multiple arrangements. Such an individual can notify
HMRC of a non-residence factor relating to all of their arrangements under the
scheme. They will need to fill in all of the sections of the form that apply to
those arrangements.
Special consideration needs to be given to an individual who is a member of a
hybrid arrangement.
Example of notifying HMRC to entitlement to a non-residence factor
Phillip
returned from an overseas secondment with an overseas resident employer on 1
June 2018. He was a relevant UK individual in the 2018-2019 tax year so he
ceased to be a relevant overseas individual with effect from 5 April 2018. At
that time he was still accruing benefits under the arrangement and had not been
paid benefits from it.
To claim an enhancement Phillip must submit a completed form APSS 202 to HMRC
no later than five years after 31 January 2019, i.e by 31 January 2024
When separate notifications of a non-residence factor are needed
Separate
APSS 202 notification forms should be submitted to HMRC in the following
circumstances.
Relevant overseas individual during more than one part of an active
membership period
Where an individual is a relevant overseas individual during more than one part
of an active membership period relating to the same pension arrangement a
separate notification should be made for each part-period.
Relevant overseas individual in more than one pension scheme
Where an individual is a relevant overseas individual during part of an active
membership period relating to more than one pension scheme a separate
notification should be made for each pension scheme.
Relevant
benefit crystallisation event occurs in an arrangement whilst the individual is
a relevant overseas individual and is still accruing benefits under the arrangement
One APSS 202 form should relate to the part of the active membership period
during which the individual was a relevant overseas individual up to the date
of that relevant benefit crystallisation event. Another APSS 202 form should
relate to the part-period from the same start date to the date of the following
relevant benefit crystallisation event. The individual should tick box 1.6 on
the second form, to show that it is amending the first notification, and should
enter on that form the reference number shown on the certificate issued in
response to the first notification. Any figures entered at box 4.1 or box 6.1
on the second form should be calculated by adding the rights or benefit
entitlement used up on the first relevant benefit crystallisation event to the
rights or benefit entitlement as at the date of the second relevant benefit
crystallisation event.
However, if the second relevant benefit crystallisation event occurs before the
end of the notification time limit relating to the first relevant benefit
crystallisation event, and before the individual has submitted a form APSS 202
in respect of the part-period up to the date of the first benefit
crystallisation event, the individual can submit one form instead of two. That
form should relate to the same part-period as would be covered by the second
form referred to above. Any figures entered at box 4.1 or box 6.1 on the form
should be calculated by adding the rights or benefit entitlement used up on the
first relevant benefit crystallisation event to the rights or benefit
entitlement as at the date of the second relevant benefit crystallisation
event. Box 1.6 should not be ticked as this form is not amending an earlier
notification. The form must be submitted within the notification time limit relating
to the first relevant benefit crystallisation event.