commence until the member attains the age of 55; at least 70% of tax-relieved funds are to provide the member with an income for life; its income from investments or deposits will be exempt from Isle of Man income tax; its administrator and at least one trustee will be resident in the Isle of Man; and its administrator will have a fixed place of business in the Isle of Man, from which the administrator’s business is conducted. Where there is reference above to “tax-relieved funds”, this is interpreted by the Assessor of Income Tax, in the context of transfers in, to be synonymous with the value of the fund transferred in. So the 50C requirement to designate at least 70% of tax-relieved funds for pension means at least 70% of transfer values received must provide a pension. This is precisely the same requirement as that which exists under UK QROPS rules (SI 2006/206). In other words, at least 70% of the transfer value into a 50C QROPS must provide a pension for life. The remainder can therefore be paid as a retirement lump sum. Any members of a QROPS who are resident or recently resident in the United Kingdom for tax purposes will be subject to member payment charges. So the maximum lump sum under a 50C scheme should be restricted to 25% of fund value if the member is subject to member payment charges, otherwise the excess would be an unauthorised member payment. The 50C legislation was officially reviewed by HMRC to ascertain if the legislation meets with the requirements set by HMRC to be a QROP scheme. On 24 June 2011, HMRC wrote to the Isle of Man Assessor of Income Tax to confirm that schemes approved under 50C were capable of meeting the QROPS criteria set by HMRC, signalling the official end to QROPS review. In December 2011, HMRC announced a change to QROPS regulations and, following consultation, revised regulations were brought in effective 6 April 2012 by SI 2012/884. The amended regulations introduced a new “benefits exemption test” for overseas schemes whose pensions are not taxed in the overseas country – that if benefits are not subject to tax, then the same tax break has to apply for local residents as it does for non-residents. To quote HMRC, the new test “removes the distortion that makes a scheme more attractive for non-residents than residents from a