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Qualifying non-UK pension scheme (QNUPS) meaning

What does Qualifying non-UK pension scheme (QNUPS) mean?
A qualifying non-UK pension scheme (QNUPS) is a non-UK pension arrangement used in cross-border estate and wealth planning to hold retirement savings outside the UK registered pensions regime while securing broadly equivalent UK inheritance tax (IHT) treatment. It is a statutory UK tax concept: the scheme must be an “overseas pension scheme” within Finance Act 2004 (FA 2004), s 150, and meet the conditions in the Inheritance Tax (Qualifying Non-UK Pension Schemes) Regulations 2010 (SI 2010/51). Where those conditions are met, contributions and scheme property benefit from IHT treatment broadly mirroring that of UK registered pension schemes. A QNUPS is not, by definition, a UK registered pension scheme. A transfer from a UK registered pension scheme to a QNUPS is not a “recognised transfer” under FA 2004, s 169 (and so may attract unauthorised payment charges), unless the receiving arrangement also qualifies as a QROPS (qualifying recognised overseas pension scheme). In practice, QNUPS are funded with non-UK tax-relieved monies and used for retirement and succession planning by individuals with a UK tax nexus. Usage and legal effect are consistent across England & Wales, Scotland and Northern Ireland. In Ireland, QNUPS is not a statutory term but is encountered in cross‑border advice where...
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View the related Practice Notes about Qualifying non-UK pension scheme (QNUPS)

PRACTICE NOTES
Private Client Glossary (England and Wales): Wills, Probate, Trusts, Capacity and UK Taxation

Private Client England & Wales glossary A Abatement When, after settling the deceased’s funeral costs, debts and liabilities, the remaining estate cannot satisfy all legacies in full, the gifts are reduced accordingly, unless the Will shows a different intention. In a solvent estate, the order for reduction appears in Part II of Schedule 1 to the Administration of Estates Act 1925. Refer to Practice Note: Payment of legacies. Accruals basis Where income is taxed on an accruals basis, it is attributed to a given tax year by reference to the number of days within that year during which the activity giving rise to the liability accrued. See Practice Note: What is the basis of income tax?. Accumulation and maintenance (A&M) trust A form of non‑interest in possession trust designed to benefit children and young people up to 25, which received favourable inheritance tax treatment between 1975 and 2006. See Practice Note: Accumulation and maintenance trusts—IHT [Archived]. Accredited Legal Representative (ALR) ...

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PRACTICE NOTES
Pensions glossary for family and matrimonial finance lawyers: schemes, tax reliefs, state pension, auto-enrolment, offsetting, PPF, valuation, drawdown and post-2024 lifetime allowance changes

A-day 'A-day' is the widely used term for the broad pension tax 'simplification' reforms that began on 6 April 2006. The changes covered: how much pension contribution was allowed, the kinds of schemes an individual could invest in, the sums that could be taken (and when), and the choices available for any remaining fund. A-day also introduced the annual allowance and the (now abolished) lifetime allowance. See: Annual allowance and Lifetime allowance. AFPS AFPS: Armed forces pension scheme; see Practice Note: Public sector pensions and family proceedings. Accrual rate The speed at which pension benefits build as pensionable service is completed in a final salary scheme, eg 1/60 for each year of pensionable service. Accrued benefits The benefits earned in respect of service up to a specified date. Added years Extra pension provided by adding further years of pensionable service in a salary-related scheme. Such additional years are secured via transfer payments or through additional voluntary contributions/augmentation...

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PRACTICE NOTES
UK pensions tax for internationally mobile employees and members: migrant relief, QOPS/QROPS and RNUKS, foreign benefits taxation, HMRC-registered schemes for non-residents, auto-enrolment, portability and transfer rules

Since A‑day (6 April 2006), key features of the UK tax regime for employees and others in foreign pension schemes are: Migrant member tax relief may reduce UK tax on contributions to a ‘qualifying overseas pension scheme’ (QOPS) in specified cases. See: UK tax relief on pension contributions to an overseas pension scheme—migrant relief, below Members of overseas pension schemes (OPS) or relevant non‑UK schemes (RNUKS) can incur UK tax charges in some situations, even if not UK resident. See: Tax treatment of pension benefits paid by a foreign pension scheme (not being a HMRC‑registered pension scheme), below Overseas individuals in HMRC‑registered pension schemes are subject to different rules. See: Tax treatment of overseas individuals who are members of HMRC‑registered pension schemes, below. UK tax relief on pension contributions to an overseas pension scheme—migrant relief UK tax relief is not automatic on contributions paid by, or for, an individual to an overseas pension scheme (OPS), a qualifying non‑UK pension scheme (QNUPS),...

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