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QROPS/QNUPS: Treating Customers Fairly

Contributed by SIPP Specialists Limited
12 October, 2011

The FSA’s treating customers fairly initiative requires advisers to take into account the client’s current circumstances, residence status and their tax position when transferring to a QROPS. Their ultimate choice of residence and the attendant taxation is the key. The choice of jurisdiction can be vital in supporting advisers under TCF and this can often be a more important consideration than the fees charged, as each jurisdiction has different rules which can make a huge tax difference depending on the client’s needs and residence of choice. If an unsuitable jurisdiction is chosen, even if the QROPS fee is NIL, this could be challenged as wrong advice, if it is not as tax efficient as another jurisdiction.

Remember that for QROPS Jurisdictions ‘one size does not fit all’

In addition the Pension Commencement Sum (the tax free cash), although free of tax in the QROPS jurisdiction may be subject to tax in the member’s country of residence. The existence of such things as double taxation agreements or tax treaties between the QROPS jurisdiction the country of residence of the member can make an enormous difference. This must be considered for potential QROPS clients, and in some circumstances the advice may be to take the tax free cash before transferring.

Remember to research the taxation in the selected country of residence

The quality of regulation may be an issue in the choice of QROPS jurisdiction. Some jurisdictions are introducing voluntary codes of conduct for QROPS providers (including Guernsey and New Zealand). The Isle of Man has an independent regulator (the Insurance and Pensions Authority) – effectively a ‘compulsory code of conduct’.

You need to know that a QROPS provider is not going to use practices which may lead to a challenge from regulators in the future, resulting in substantial tax charges, and that they will offer robust and efficient administration with appropriate software. You will also need to be aware of any hidden fees or charges – commissions, bank account or investment charges.

Please also remember that the only FSA regulated entity in the whole exercise may be YOU.


  • Choice of QROPS Jurisdictions: IOM, Malta, Guernsey, Gibraltar
  • IOM QNUPS (residential property allowed)
  • Consultancy and support
  • Transparent, consistent fee structure
  • Quality administrative support
  • Dedicated team of specialists
  • Open architecture investment approach
  • An approach which follows both spirit and letter of QROPS legislation
  • The use of a UK SIPP as a collection point if required

Oaklands Park, Hooton Road, Hooton, South Wirral, CH66 7NZ
Tel: 0151 328 0594 Fax: 0151 328 0707 www.sippspecialists.co.uk

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


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