The funding of retirement is a complex issue in the international context because of radically different approaches taken by different countries. The UK treatment has been unified by ITEPA 2003, Pt. 9, which provides for the taxation of pension income, and FA 2004, Pt. 4, which provides for the tax treatment of pension schemes and similar arrangements. The vast majority of treaties and the OECD Model do not deal explicitly with the treatment of contributions to pension schemes or the taxation of those schemes, although increasingly these issues are addressed in modern treaties.99

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