Scenario: A British domicile returned to the UK from Hong Kong nearly 3 years ago (he was there for 8 years and was Not Resident). He was employed by a French employer with a regional office in HK. Whilst there he built up a pension in a Hong Kong pension scheme. Even though he is younger than the UK pensionable age, he can take out the entire fund as cash now and bring it back to the UK.
We are struggling to determine whether there would be any UK tax liability if he cashes the pension in & moves the money back to the UK. Investigation appears to suggest that there would be little or no liability as all of the value accrued prior to 6 April 2017. [We believe there would be no liability for the sum transferred that relates to pension funds accrued before 6 April 2011; and for the pension pot accrued after that date but before 6 April 2017, we believe that either there is no liability, or at worst there may be a little liability for the sum transferred to the extent he was not 100% working out of the UK (he spent 1 month working on a project in the UK during 2012, whilst still remaining employed by the HK branch of the French employer).
Question: can anyone help with advice about whether there would be a UK income tax liability?
I am aware that the rules changed on 6 April 2017, for pensions accrued from that date onwards only (clarified in a Government article on 20 April: https://www.gov.uk/government/publications/pension-tax-for-overseas-pensions-additional-information/pension-tax-for-overseas-pensions-additional-information