Qualifying non-UK pension schemes (QNUPS)

Produced by Tolley

The following Employment Tax guidance note Produced by Tolley provides comprehensive and up to date tax information covering:

  • Qualifying non-UK pension schemes (QNUPS)
  • Introduction
  • The legislative framework
  • Conditions to be a QNUPS
  • QROPS / QNUPS and IHT planning
  • Consultation on uniformity of IHT treatment for UK-registered pension schemes and QNUPS

Qualifying non-UK pension schemes (QNUPS)


The inheritance tax exemptions that apply to UK-registered pension schemes generally were not extended to Qualifying Recognised Overseas Pension Schemes (QROPS) in FA 2004. The result was an unsatisfactory position where, strictly according to the law, the exit charge and periodic charges associated with discretionary trusts applied to a QROPS. When this was brought to HMRC’s attention it was recognised as an unintended error.

As a result, SI 2010/51 was made to correct the position, introducing a new acronym into the pensions vocabulary, ‘QNUPS’.

The legislative framework

QNUPS are referred to in IHTM17025 as follows:

‘A qualifying non-UK pension scheme (QNUPS) is entitled to the same exclusions from Inheritance Tax as a registered pension scheme but they will not necessarily provide similar pension benefits or be structured in a similar way.

A QNUPS is defined in IHTA 1984, s 271A as a pension scheme that is not a registered pension scheme but is established in a country or territory outside the UK and meets the requirements of SI 2010/51.

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