101760 – Financial Accounts: Excluded Accounts: Retirement & Pension Accounts

All retirement accounts and products established under a:

  • UK registered pension scheme under Part 4 of the Finance Act 2004; and
  • Non-registered pension arrangements, including arrangements with overseas pension funds, where
  • Annual contributions are limited to £50,000; and 
  • The funds contributed cannot be accessed before the age of 55, except in circumstances of serious ill health

are in Annex II of the IGAs and are substantially similar to the definition of retirement accounts in Section VIII C(17)(a) of the CRS and DAC. Consequently, they are Excluded Accounts, and financial institutions will have no due diligence or reporting obligations in respect of these accounts or products. For clarification, this applies to both the accumulation and decumulation phases of a pension scheme, contract or arrangement. 


Registered Pension Scheme

A registered pension scheme is a pension scheme or contract that is registered with or deemed registered with HMRC. Any pension scheme or contract that had tax approval on 5 April 2006 (or whose tax approved status was granted on or after 6 April 2006, but was backdated so that the scheme was in effect adopted on 5 April 2006) automatically became a registered pension scheme from 6 April 2006.

A deferred annuity “buy-out” contract that secures benefits that have arisen under a registered pension scheme is treated as a registered pension scheme from the date it is purchased.

Accumulation and Decumulation Phase

The accumulation phase is the accumulation of savings (or accrual of benefit) in a registered pension scheme or another pension arrangement.

The decumulation phase is the use of those accumulated funds to take a pension for the remainder of the individual’s or their dependant’s life.

“Pension” is defined under Section 165 (2) Finance Act 2004, to include an annuity or income withdrawal as well as a pension that is paid directly from the pension scheme.