Overseas pension schemes: reporting requirements
Details of your reporting requirements for overseas pension schemes.
- pension input period for an overseas pension scheme must correspond to the tax year
- amount of a member’s pension input must only relate to the proportion of their earnings that are chargeable to UK tax
The annual allowance scheme rules also apply to members of overseas pension schemes. You should fill in form APSS210 to tell HM Revenue and Customs (HMRC) the overseas pension scheme will pay the annual allowance charge on behalf of a scheme member.
Find more on the application of the annual allowance charge to overseas pension schemes in the Pensions Tax Manual.
Money purchase annual allowance
Scheme managers of qualifying recognised overseas pension schemes (QROPS) must report information about benefit crystallisation events for relevant migrant members of the scheme.
You should give this information by 31 January following the end of the tax year in which the benefit crystallisation event occurs.
Fill in APSS252 to do this.
Transfers from registered pension schemes to QROPS
If a scheme member requests a transfer from their UK scheme to a QROPS, the UK scheme administrator has to notify HMRC of the transfer and provide details of the relevant QROPS. Overseas scheme managers may be asked to provide this information to the UK scheme administrator.
Payments from a QROPS
You must tell HMRC about payments made or treated as made in respect of relevant members (and their relevant transfer funds). These can be pension payments, lump sum payments, annuity purchases or transfer payments and include payments made under the pension flexibility rules.
Use form APSS253 to tell HMRC about these payments.
Usually you must report the payment (or deemed payment) to HMRC within 90 days of the date of the payment (or deemed payment). However this only applies when the payment is made from funds transferred to a QROPS in the last 10 years, unless the member payment provisions apply.
Find more about the member payments provisions in the Pensions Tax Manual.
Uncrystallised funds pension lump sums (UFPLS)
The equivalent of an UFPLS paid from one of these overseas schemes is taxed in the same way as if it was from a registered pension scheme. However the lifetime allowance provisions are slightly different.
When calculating the member’s available lifetime allowance, the value of 2 benefit crystallisation events (BCE) will be disregarded. They are:
- BCE 8 - where there is a transfer from a registered pension scheme to a QROPS
- the elected BCE - where a member who has pension savings under an overseas pension scheme and has received UK tax relief, elects to take their BCE at a date they have chosen
This will prevent a sum being allocated twice out of the lifetime allowance – once when the BCE took place and again when payment of the UFPLS equivalent is made.
Pension flexibility reporting requirements
The scheme manager of a QROPS or former QROPS must give the member a flexible access statement within 91 days of the date of one of the following ‘relevant events’:
- when a qualifying payment is made from a flexi-access drawdown fund created from funds designated on or after 6 April 2015
- at the start of 6 April 2015 if the member had the flexible drawdown pension fund before 6 April 2015
- when a qualifying payment is made from a flexi-access drawdown fund created by the conversion of the member capped drawdown pension fund at the member’s request
- where a payment is made from a capped drawdown pension fund that’s more than the annual capped drawdown limit and so converts the fund into flexi-access drawdown
- the payment of an uncrystallised funds pension lump sum
The member must also have been either:
- UK resident when the relevant event occurred
- a UK resident in any one of the previous 5 tax years
You can find more information in the Pensions Tax Manual.