QROPS: An Overview of Jurisdictional Differences
Contributed by SIPP Specialists Limited
05 February, 2013
Contributed by SIPP Specialists Limited [www.sippspecialists.co.im]
The following factors are common amongst all jurisdictions only the differences are highlighted under each jurisdiction.
- 30% PCLS for non UK residents subject to time outside UK tax system
- No tax on surplus on death for non UK residents subject to above
- Outside of UK IHT
- No limit to fund size/contribution for non UK residents subject to above
- No need to purchase an annuity
Is still a viable QROPS Jurisdiction since HMRC rule change in April 2012
- Pension income paid gross (subject to PIE status)
Spent two years in discussions with HMRC prior to attaining QROPS Status. Has recently issued a Code of Conduct for QROPS providers there.
- Full member of EU
- Large number of DTA in place
- 35% withholding tax on pension income if no DTA in place
Has recently been given the green light by HMRC to resume QROPS business and has recently issued a Code of Conduct for its QROPS providers
- A member of the EU by association
- 2.5% withholding tax on pension income
- Flexible income withdrawal a possibility
- Possible lending facility available
- Early retirement options available for sportspeople for example
Isle of Man
Recent HMRC rule changes means that it is really only viable for IOM resident QROPS, although some are attracted to its strong reputation as a jurisdiction.
- Early retirement option for sports people for example
For residents of Australia only.
- 100% cash commutation available
- Some transfer limits apply
This is only an overview but highlights some of the factors advisers need to take into account when considering QROPS jurisdictions. There are more issues.
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SIPP Specialists Limited - Registered in England and Wales Registered No 4845017
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QROPS and QNUPS Choice Ltd Registered in Gibraltar - Registered number 108379
Registered Office: Gibro House, Suite 4, 4 Giros Passage, Gibraltar
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