Types of overseas pension schemes
Produced in partnership with Stephenson Harwood and Fraser Sparks of PwC
Types of overseas pension schemes

The following Pensions practice note produced in partnership with Stephenson Harwood and Fraser Sparks of PwC provides comprehensive and up to date legal information covering:

  • Types of overseas pension schemes
  • Interrelationship between the different types of overseas schemes
  • Interrelationship between overseas schemes
  • Inheritance tax treatment
  • Distinguishing between QNUPS and QROPS
  • Interrelationship with EFRBS
  • Overseas Pension Scheme (OPS)
  • Where is a pension scheme established?
  • The 'international organisation' condition
  • 'The 'relevant regulation' condition
  • More...

Types of overseas pension schemes

There are different categories of overseas pension schemes, with various layers of requirements. These include:

  1. Overseas Pension Schemes (OPS)

  2. Qualifying Non-UK Pension Schemes (QNUPS)

  3. Recognised Overseas Pension Schemes (ROPS)

  4. Qualifying Recognised Overseas Pension Schemes (QROPS)

Interrelationship between the different types of overseas schemes

Interrelationship between overseas schemes

A QROPS is a ROPS which has notified HMRC of that fact and has provided evidence of that fact.

A ROPS and a QROPS will always be an OPS. However, an OPS will not be a ROPS or QROPS without further requirements being satisfied.

An OPS will always be a QNUPS. A QNUPS will often be an OPS, but due to a small difference in requirements between an OPS and a QNUPS, there may be limited circumstances where a QNUPS will not be an OPS.

Inheritance tax treatment

For a period of time post A-day (ie 6 April 2006), the only pension schemes that enjoyed an exemption from inheritance tax were registered pension schemes for the purposes of Part 4 of the Finance Act 2004 (FA 2004) (UK registered pension schemes). To this day, death benefits payable under registered pension schemes are generally free of inheritance tax. For more information, see Practice Note: Tax treatment of pensions—an introduction — Death benefits paid by registered pension schemes.

The absence of an exemption for overseas pension schemes was apparently due to an accidental

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