Managing overseas pension schemes
Guidance for managers of overseas pension schemes on the different types of overseas pension schemes and what they need to report to HMRC.
Types of overseas pension schemes
The pension tax rules cover different types of overseas pension schemes. These are:
- overseas pension schemes
- recognised overseas pension schemes (ROPS)
- qualifying overseas pension schemes (QOPS)
- qualifying recognised overseas pension schemes (QROPS)
- relevant non-UK schemes (RNUKS)
You have to report some payments to and from these schemes and notify HM Revenue and Customs (HMRC) of the scheme status to ensure these payments aren’t treated as unauthorised payments.
Overseas pension scheme
An overseas pension scheme is one that’s not a registered scheme, but is established in a country or territory outside the UK and meets certain requirements. You can tell HMRC about overseas pension schemes using form APSS250.
A ROPS is an overseas pension scheme that also meets:
- the Benefits Tax Relief Test (unless the scheme is set up by an international organisation or is an overseas public service pension scheme)
- the Pension Age Test
- one or more of the further requirements
Overseas public service pension schemes and schemes set up by an international organisation do not have to meet either The ‘Benefits Tax Relief Test’ or The ‘Pension Age Test’ to be a ROPS.
List of schemes that have notified HMRC that they meet the ROPS conditions
HMRC publishes a list of recognised overseas pension schemes notifications it has received.
The list allows scheme administrators of registered pension schemes and overseas pension scheme managers to check whether an overseas pension scheme has notified HMRC it meets the conditions to be a ROPS. If a scheme isn’t on the list, HMRC can only confirm that the scheme has sent a notification if they have written permission from the overseas scheme manager to do so.
The published list is usually updated twice a month by Pension Schemes Services. A scheme’s name will be removed from the published list once HMRC is aware it has ceased to be a ROPS or never met the conditions to be one.
Overseas scheme managers can request the name of the ROPS scheme to be published on GOV.UK when completing form APSS251 to notify HMRC of the ROPS status. Not all ROPS are on the published list.
Removal from the list
You can ask for your scheme to be removed from the published list. If a scheme is removed from the list it may still be a ROPS. For example, the status of the scheme may have changed and it may no longer meet the requirements to be a recognised overseas pension scheme or HMRC may have excluded the scheme from being a QROPS.
Due to confidentiality rules, HMRC can’t say why a particular entity is no longer included unless it receives written authorisation from you to give this information to a named individual.
HMRC will usually pursue any UK tax charges (and interest for late payment) arising from transfers to overseas entities that don’t meet the ROPS requirements even when they appear on this list. This includes where taxpayers are overseas. HMRC will also charge penalties in appropriate cases.
You can find more about the list of ROPS notifications in the Pensions Tax Manual.
If HMRC has concerns about an entity at any time its name may be removed from the published list while it carries out further checks.
QROPS must meet certain HMRC requirements. To be a QROPS the ROPS must:
- meet the ROPS requirements
- notify HMRC that the scheme meets the ROPS requirements
- agree to provide information to HMRC, other pension schemes and individuals
- notify HMRC if the scheme ever ceases to be a ROPS
You must notify HMRC of your ROPS status every 5 years from the date that HMRC gives you your QROPS number.
A QOPS is an overseas pension scheme where HMRC has not excluded the scheme from being a qualifying overseas pension scheme and the overseas scheme manager has:
- notified HMRC that it meets the conditions to be an overseas pension scheme and provided any evidence HMRC may need
- undertaken to tell HMRC if the scheme ceases to be an overseas pension scheme
- undertaken to comply with the prescribed benefit crystallisation information requirements
RNUKS pension schemes are currently tax relieved overseas schemes where UK tax relief has been given on or after 6 April 2006 in respect of pension savings under the scheme.
Published: 6 April 2015
Updated: 1 October 2015
- Amended to include the ROPS re-notification process and how pension scheme managers re-notify HMRC of their scheme status.
- First published.