Readers’ forum: Overseas pension

Following a period of employment in France our client is due to receive two pensions. Under the plan d’epargne groupe (PEG) and plan d’epargne retraite complementaire (PERCO) schemes both are to be paid as a lump sum. No tax relief was obtained in France on the contributions to these schemes. The client was employed in France from January 2009 to May 2014.

The benefits all arose from payments made into the schemes during this period of employment and the schemes only became payable after the client’s retirement.

We understand that under ITEPA 2003 s 395B (formerly concession A10) lump sums paid under overseas pension schemes are not charged to income tax if the employee’s overseas service comprises:

• not less than 75% of their total service in that employment; or
• the whole of the last ten years of the service in that employment where total service exceeds...