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Specific requirements apply under EU law to pension schemes that operate across different member states. However, the cross-border rules allow member states a degree of flexibility. Transitional arrangements were put in place by the Westminster Government and Ireland when these rules were introduced and we consider that it will be possible to agree transitional arrangements for existing UK-wide schemes. The Scottish Government is keen to start discussions with the Westminster Government and the European Commission as soon as possible, with a view to reaching agreement in the interests of employers and pension schemes across the UK.

Source: Scotland's Future, Scottish Government, November 2013.