Further submission by the CIOT on the draft Bill, sent to the Inland Revenue on 19 November 2002. In the brief time available we have circulated these papers but have not received any feedback on them by your deadline of noon today.
The only comment we have is that it seems slightly odd, in the new Chapter 2 of the Pension Income Part, to see a deduction in arriving at the net taxable pension income for 10% for overseas government pensions (new clause 3(5)), but not to see the same deduction for other foreign pensions, as given by original clause 568(1).
Perhaps this has something to do with the wording you are using in the new "section 53", referred to in new clause 3(5), but which we do not have sight of. We note that original clause 609 gave the 10% relief for overseas government pensions by charging 90% of the pension to tax. Is this clause also now changing?
Is there a special reason for not including the 10% deduction for other foreign pensions in new clause 3(5)?
Please regard these comments as informal as there has not been time for us to put them on a more formal basis.
Technical Department
020 7235 9381
