s 239 Scheme sanction charge
(1) A charge to income tax, to be known as the scheme sanction charge, arises where in any tax year one or more scheme chargeable payments are made by a registered pension scheme. (2) The person liable to the scheme sanction charge is the scheme administrator. (3) But — (a) in the case of a payment treated by virtue of section 161(3) and (4) (payments under investments acquired with scheme assets) as having been made by a pension scheme which has been wound up, the person liable to the scheme sanction charge is the person who was, or each of the persons who were, the scheme administrator immediately before the pension scheme was wound up, ... (b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (3A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . (4) A person liable to the scheme sanction charge is liable whether or not— (a) that person, and (b) any other person who is liable to the scheme sanction charge, are resident ... ... in the United Kingdom. (5) The following sections make further provision about the scheme sanction charge— section 240 (amount of charge), and section 241 (scheme chargeable payment). (6) This section is subject to provision made by regulations under section 273ZA (income and gains from taxable property).