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Posted Thu, 17 Aug 2023 15:29:48 GMT by
I am UK resident with an overseas pension scheme (IPS) held in Sweden. My understanding is that an IPS account is recognised as an overseas pension scheme because it is regulated (in other words has special treatment and rules saying what it can and cannot invest in) and any withdrawals at or before reaching pension age is taxable as personal income. This appears to satisfy the requires set out in PTM112200. However, due to a lack of consideration by the Swedish tax authorities there is still a provision to tax any dividends received from investments back into the fund at 5%, which effectively creates a localised double taxation for holders who are no longer resident in Sweden but resident in the UK, as per the double taxation treaty. These events I presume may have been shared with the HMRC who might then consider that some kind of dividend distribution has taken place, whereas in fact it has not. I am now wondering if the HMRC perceives any reallocation or dividend events taking place within the scheme as being subject to personal taxation by a holder who is UK resident? I am here referring to events that take place within the scheme, not withdrawals or anything paid out of the scheme, since the rules prohibit any withdrawals until certain conditions are met. I am asking because it seems the HMRC believe there is foreign income undeclared and I don't know what else there is which would be of interest if not this.
Posted Fri, 18 Aug 2023 15:20:19 GMT by HMRC Admin 25 Response
Hi Per Olausson,
This would suggest that the dividend is in your name and automatically reinvested and as such would be your income.
Tax would be due if it exceeds the dividend allowance each year and you can claim foreign tax credit relief if applicable.
Tax on dividends
Thank you. 

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