TSEM5360 | Trusts for particular purposes: employment-related trusts: retirement benefits: ICTA88/S615 schemes - introduction
From HM Revenue & Customs · Trusts, Settlements and Estates Manual
Where an unapproved retirement benefits scheme meets certain requirements in S615 ICTA 1988:
the trust is exempt to an extent from income tax and capital gains tax
the trustees may pay annuities free of tax
employees may receive sums tax free
but income arising in the UK to UK resident trustees remains taxable.
No new S615 schemes can be established after 5 April 2017. If an existing scheme receives contributions from 6 April 2017, that part of the fund will not be treated as having S615 status.
Whether a scheme meets S615 conditions should be considered by Pension Scheme Services.
Such trusts will be dealt with by BT & C Trusts under normal SA procedures.