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What is a QNUPS?

QNUPS – Qualifying Non‑UK Pension Schemes

Qualifying Non‑UK Pension Schemes were introduced by HMRC through statutory instrument 51 which came into force on 15th February 2010, but which was effective from 6th April 2006 (A‑day). This defined the parameters that overseas pensions would need to meet to qualify as a non‑UK Pension Scheme and how these schemes would be treated for UK tax purposes whilst the member was contributing; in benefit payment (drawdown) and how any residual value of the pension would be treated after the member’s death (i.e. whether UK Inheritance Tax (IHT) is applicable or not).

Whilst a “UK registered pension” has limits imposed on it with regard to the UK tax relief available “Life Time Allowance”, a QNUPS has the advantage that as it does not hold UK tax relieved funds (i.e. contributions are paid after tax), and therefore, there are no limits on the pension fund size. Thus making it an ideal supplementary pension.

Gower Pensions Management QNUPS structures are established through a Guernsey retirement annuity trust scheme. As a trust structure, the assets held are in the legal ownership of the trust and not the member, but held for the member’s benefit. Upon the member’s death, any residual value will normally fall outside of a member’s estate, and will be held by the Trustee. The Trustee will distribute any residual value, normally directly to nominated beneficiaries of the late member, at the Trustee’s discretion and in accordance with the Plan rules.

QNUPS structures can be established by Guernsey residents; UK residents and other non‑Guernsey residents around the world. The opportunities and benefits may vary depending on where the member and their subsequent beneficiaries are tax resident.

Gower Pensions Management Limited do not provide tax, legal or financial advice and recommend that specialist advice is sought prior to establishment.

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