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Kiwi Saver

A friend asked me to post this, and if any of you lovely people could offer any thoughts;


Does a full withdrawal from a New Zealand KiwiSaver scheme by a UK-resident
individual, who became UK resident in September 2019 and has never received UK
tax relief on KiwiSaver contributions, constitute taxable foreign pension income under
sections 573–574A ITEPA 2003, or is any part of the withdrawal properly characterised
as a non-taxable return of capital?


More specifically:
 Whether KiwiSaver is a "foreign pension" for the purposes of Part 9 ITEPA 2003.
 The correct UK tax treatment of a full withdrawal after becoming UK resident.
 Whether the withdrawal should be analysed as:

  • pension income
  • a foreign pension lump sum,
  • or a return of capital.


 Whether there is a basis for seeking HMRC clearance before any withdrawal.
 The relevance of the UK–New Zealand Double Taxation Convention.
 Whether any part of the withdrawal is outside the UK tax charge.
 The UK tax treatment of subsequently using the proceeds to purchase a
Purchased Life Annuity.

He appreciates it’s a niche topic, but just wondered if anyone had any knowledge of this, many thanks

I’m a Forum Ambassador and I support the Forum Team on the Pension, Debt Free Wanabee, and Over 50 Money Saving boards. If you need any help on these boards, do let me know. Please note that Ambassadors are not moderators. Any posts you spot in breach of the Forum Rules should be reported via the Report button, or by e-mailing forumteam@moneysavingexpert.com. All views are my own and not the official line of MoneySavingExpert.

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