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The taxpayer company was the trustee of a pension scheme based in Singapore.
An issue arose as to whether the scheme was a qualifying recognised overseas pension scheme for the purposes of FA 2004, s 150(8).
For it to so qualify, the scheme would have to satisfy the conditions in the Pension Schemes (Category of Country and Requirements for Overseas Pension Schemes and Recognised Overseas Pension Schemes) Regulations SI 2006/206.
The High Court held it was not a qualifying scheme. The company appealed.
The Court of Appeal found that condition B of regulation 2(3) could be satisfied only if the country in which the pension scheme was based had no system of approval or recognition for pension schemes.
Singapore did have such a system, meaning the condition could not be satisfied.
The taxpayer company’s appeal was dismissed.
