On 15 August 2025, Revenue published an update to Chapter 13 of the Pensions Manual, which deals with the transfer of pension benefits. The revised guidance sets out the conditions under which transfer payments from occupational pension schemes may be made to PRSAs, and also to another exempt approved scheme, or a buy-out-bond, particularly in relation to the timing and tax treatment of such transfers. The Manual has also been amended to provide guidance in relation to transfers from overseas arrangements to an Irish scheme, and from an Irish scheme to overseas arrangements.
The updated guidance in Chapter 13 of the Revenue Pensions Manual states that transfers of pension benefits may not be permitted once those benefits have “become payable”. It states that the point at which benefits become payable is determined by the rules of the specific pension scheme, and that in most cases, this occurs at Normal Retirement Age (“NRA”).
Where benefits have reached this payable stage – often at NRA – transfers out of the scheme are generally not allowed. This interpretation reinforces the importance of reviewing scheme rules carefully. Trustees should consider their specific scheme rules in this regard before effecting any transfers and take appropriate advice. It should also be noted that this update to the Revenue Pensions Manual refers expressly to transfers in accordance with the Taxes Consolidation Act. Transfer payments in respect of preserved benefits are subject to additional considerations under the Pensions Act which may override the Scheme rules.
This article contains a general summary of developments and is not a complete or definitive statement of the law. Specific legal advice should be obtained where appropriate.
