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Access all documents on Qualifying non-UK pension schemes (QNUPS)

Qualifying non-UK pension schemes (QNUPS) meaning

What does Qualifying non-UK pension schemes (QNUPS) mean?
A qualifying non-UK pension scheme (QNUPS) is a non-UK pension that, if it meets statutory conditions, is treated for UK inheritance tax (IHT) broadly like a UK-registered pension. It is defined for IHT purposes in the Inheritance Tax (Qualifying Non-UK Pension Schemes) Regulations 2010, effective from 15 February 2010 with retrospective effect to 6 April 2006 (A‑Day). Key features and effect: - Contributions to, and assets held within, a QNUPS are generally not treated as transfers of value and are typically outside the member’s estate for IHT, mirroring the position for registered pension schemes. - No UK tax relief is available on contributions. - A UK-registered pension can only be transferred overseas to a recognised overseas pension scheme (ROPS). QNUPS status alone does not permit a transfer, although a scheme may qualify as both a QNUPS and a ROPS. - The scheme must operate as a genuine pension (benefits payable only on retirement, ill-health or death), or IHT/anti-avoidance risks may arise. In practice, QNUPS are used in cross-border estate planning for high earners intending to retire abroad and for non-UK-domiciled or internationally mobile individuals with UK IHT exposure. IHT is a UK-wide tax, so treatment is consistent across England & Wales, Scotland...
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View the related Practice Notes about Qualifying non-UK pension schemes (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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