In sickness and in health

Published: 25 Nov 2016

Philip Hammond delivered his first full UK Budget speech on Wednesday 8th March 2017, and delivered significant news for the International Pensions industry.

Full details of the specific measures can be found here, which will be analysed in detail by us.

In summary

Transfers to QROPS requested on or after the 9th March 2017 will be subject to a 25% tax charge, unless;
1. The QROPS is in the EEA and the Member is also resident in a EEA country.
2. The QROPS and Member are in the same country or territory. This is a limited if negligible part of the market.
3. The QROPS is an employer sponsored occupational scheme, overseas public service pension scheme or a pension scheme established by an international organisation.
Draft Guidance confirms that for the purposes of these measures, the EEA includes Gibraltar, which is considered part of the EU as a part of the UK.
These measures take effect for any transfer from a UK Registered Scheme requested from tomorrow.
Guidance is provided on the “date of transfer request” in section 2.22 of the Overseas Transfer Charge – Guidance (available here). In addition the Member must have provided the Scheme Administrator with all the required prescribed information before the transfer is made.

What is the impact?

1. For Members who are resident within the EEA, it would appear from first reading that there should be no impact for transfers to the Momentum Malta Retirement Scheme or the Momentum Gibraltar Pension Plan, provided there is no change to the Member EEA tax residency status within five full tax years from date of transfer.
2. We are currently assessing the impact in relation to the Isle of Man.
3. For Non EEA resident Members, an alternative is to effect a transfer to the Momentum International SIPP. QROPS would appear to be broadly unsuitable for anyone residing outside the EEA or who intends to relocate outside the EEA within the next five full tax years.
The above charge will also apply for any future QROPS to QROPS transfers, where the original transfer to the QROPS related to a transfer from a UK Registered Scheme which was requested on or after 9th March 2017.


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