Canadian RRSP/RRIF lump sum withdrawal - tax in UK

How should RRSP/RRIF lump sum withdrawals be taxed in the UK? Availability of FTCR?

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I have reviewed HMRC guidance at DT4605 and read the responses to the below previous question:

There still seems to be some doubt/confusion on this - not least at my end, especially having read that some readers have not taxed the lump sum withdrawal at all in the UK.   I have a new client who has reported such lump sums historically as income and claimed FTCR.   I am aware that this is may well not be correct where funds in the RRSP/RRIF have accrued prior to 6 April 2017.  Should these have been treated as transparent and all underlying gains/dividends have been reported on respective tax returns (heaven knows how I'm going to establish these figures), or should I only be working on the capital gain on the disposal of any assets to fund the lump sum withdrawal on a proportional basis where some funds have accrued pre 6 April 2017?  

HMRC are querying the FTCR claim, but they don't even seem capable of explaining how they think this should have been treated, or actually asking a question - they just quote DT4605 verbatim, but want to treat the whole lump sum as income on the UK return, but without any FTCR applying.   Surely, if it's not income for the purposes of FTCR, then it can't be taxed as such. 

Any assistance would be much appreciated from anyone with prior experience or knowledge.


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