Section 50C of the Isle of Man Income Tax Act 1970 is an Act of Tynwald (the Parliament of the Isle of Man) which created a new type of pension arrangement, adding to the Isle of Man’s existing local and international pension legislation. Pension schemes approved under 50C met the applicable HMRC regulations on Qualifying Recognised Overseas Pension Schemes (QROPS) until 5 April 2012 when the regulations changed. Background In the period following A-day, the new UK pension framework introduced by the Finance Act 2004 led many more British expatriates to transfer their UK (occupational and personal) pensions to overseas pension schemes (termed QROPS) approved for this purpose. A small number of international finance centres quickly became popular with specialist pension providers seeking to establish QROPS. The Isle of Man, whilst a popular centre, with many schemes approved on the QROPS list, was not initially the most attractive QROPS location, because the existing Isle of Man pensions tax framework meant that pensions payable from Manx pension schemes were, in many cases, subject to Isle of Man income tax at source. This was uncompetitive compared to some other QROPS centres whose schemes could, by exemption or otherwise, pay pensions gross, without deduction of tax. The new 50C legislation was introduced into Isle of Man law on 22 October 2010, to create a new pensions taxation framework specifically designed to satisfy the QROPS requirements, and to permit the payment of pension and other benefits free of Isle of Man tax, and in doing so to position the Isle of Man as the premier centre for QROPS business. Overview The new legislation was introduced by Order under section 15 of the Income Tax Act 1995. The Income Tax (Pensions) (Temporary Taxation) Order 2010 (SD 807/10) amended the Income Tax Act 1970 by inserting a new section 50C headed "50C Relief for certain personal and occupational pension schemes." The main characteristics of a 50C scheme are: it is available to residents and non-residents of the Isle of Man; it is registered with the Insurance and Pensions Authority; it is tax-approved by the Assessor of Income Tax to ensure that it satisfies the statutory requirements; it is properly established under irrevocable trusts governed by the laws of the Isle of Man; its sole purpose must be to provide relevant benefits for the member; unless the ill health condition is met, the payment of benefits cannot