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QROPS: An Overview of Jurisdictional Differences

Contributed by SIPP Specialists Limited
05 February, 2013


Contributed by SIPP Specialists Limited [www.sippspecialists.co.im]

The sole purpose of this leaflet is to highlight the jurisdictional differences that can distinguish one QROPS Jurisdiction from another when it comes to making a choice as to which jurisdiction is suitable for a client. It is not exhaustive. If you want to research further, including QROPS rules please visit www.sippspecialists.co.uk

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

New Zealand
Is still a viable QROPS Jurisdiction since HMRC rule change in April 2012

  • Pension income paid gross (subject to PIE status)

Malta
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

Gibraltar
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

Australia
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.

If you want to discuss this further, or want to research more, please visit www.sippspecialists.co.uk  or contact us on consultants@sippspeciaists.com

SippSpecialists Limited
Oaklands Business Park
Hooton Road
South Wirral
Cheshire    CH66 7NZ

T: 0151 328 0594
F: 0151 328 0707
e-mail: consultants@sippspecialists.com

SIPP Specialists Limited - Registered in England and Wales Registered No 4845017
Registered office: Montrose House, Clayhill Park Neston CH64 3RU
Tel: 0151 328 0594

QROPS and QNUPS Choice Ltd – Registered in Gibraltar - Registered number 108379
              Registered Office: Gibro House, Suite 4, 4 Giro’s Passage, Gibraltar


 




 


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