The lifetime allowance is enhanced in relation to a benefit crystallisation event (‘BCE’) where, during any part of his active membership period of a registered pension scheme, the individual:

is not a relevant UK individual (see ¶376-150); or

is only a relevant UK individual by virtue of being UK resident at some time in the previous five tax years and is not employed by a person resident in the UK

(FA 2004, s. 221(1), (3)).

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