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Tax Treatment of the PEPP: The New Pan-European Personal Pension Product

Regulation 2019/1238 concerning a pan-European personal pension product has entered into force on 14 August 2019. As a result, it 
becomes much easier for EU citizens to contribute to a personal pension product on a voluntary basis. It is expected that as from 
2021, financial institutions are able to offer a pan-European personal pension product (PEPP) to EU citizens. The tax treatment of 
the PEPP is not included in the Regulation. However, ECJ case law on tax treatment of private pension products is applicable. In this 
article, the tax treatment of the PEPP is analysed. The focus of this article is on tax related aspects in case of contributions to a PEPP 
in one Member State, while receiving PEPP retirement benefits in another Member State. The article among other discusses granting 
tax incentives to the PEPP by Member States, taxation of PEPP retirement benefits in case a tax treaty is applicable and taxation in 
case the accumulated capital of a PEPP or the saver moves to another Member State.