This could conceivably be taxable under ITEPA 2003 Pt 7A (disguised remuneration), ITEPA 2003 Pt 9 Ch.4 (foreign pensions, which now includes a relevant lump sum) or ITEPA 2003 Pt 6 Ch.2 (relevant benefits provided under an EFRBS). In each case, if a charge arises, it is a liability of the widow. However, if article 17 of the UK/Hong Kong double tax treaty applies, no UK tax liability will arise.
Matthew Harrison
Withers LLP