Chapter 2C, Part 30, TCA 1997 imposes a ring-fenced Schedule D, Case IV, tax charge (“chargeable excess tax”, or CET), at the higher rate income tax, on the crystallisation of benefits from Irish approved pension arrangements in excess of a limit called the standard fund threshold, which is currently €2m. The tax is paid by the retiree’s retirement benefits being “reduced so as to fully reflect the amount of tax so paid” (s787Q(5) TCA 1997). How this reduction happens varies between private and public sector pension arrangements, as we shall see later. The effect of Chapter 2C is to claw back at retirement the notional higher-rate tax relief granted on pensions that are deemed to have benefited from excessive pension tax relief. Chapter 2C is therefore titled “Limits on Tax-Relieved Pension Funds”. The Minister for Finance has commissioned a review of the standard fund threshold, which is expected by summer 2024.
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