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Comparison of QROPS jurisdictional rules

The table below gives a broad comparison of some of the benefits and taxation rules that can be taken from a QROPS that would apply in certain jurisdictions based on the client being and remaining a non-UK resident. This is not a comprehensive list.

  U.K. Malta Gibraltar Isle of Man
Income levels allowed Uncapped income levels allowable 150% GAD within 5 years of UK residency from UK originated funds. Post April 2015 full flexibility has been introduced by legislation. 150% GAD within 5 years of UK residency from UK originated funds. 150% GAD within 5 years of UK residency from UK originated funds.
Local tax potentially payable Members marginal tax rate Up to 35% if no double taxation treaty Withholding tax of 2.5% applied Up to 20% if no double taxation treaty
Maximum PCLS allowable 25% of fund value 25% from the UK tax-relieved scheme funds. Any growth or contributions made outside the UK subject to local rules 30% from the UK tax-relieved scheme funds. Any growth or contributions made outside the UK subject to local rules 30% from the UK tax-relieved scheme funds. Any growth or contributions made outside the UK subject to local rules
Min age for pension 55 55 for funds derived from UK. 55 55
Maximum age for pension none 70 75 75
Death benefits before age 75 Tax free Tax free Tax free Tax free
Death benefits post age 75 Taxed at recipient beneficiaries marginal rate Tax free * Tax free* Tax free*
Pensions Regulator? yes yes yes yes
Double taxation agreements available? yes yes yes yes
Fund protection? yes Not for pensions Not for pensions Yes for cash in pensions
  *non UK resident

 

Created September 2016

The information provided in this article is not intended to offer advice.

It is based on Old Mutual International's interpretation of the relevant law and is correct at the date shown at the top of this article. While we believe this interpretation to be correct, we cannot guarantee it. Old Mutual International cannot accept any responsibility for any action taken or refrained from being taken as a result of the information contained in this article.

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