HMRC internal manual

Inheritance Tax Manual

IHTM17025 - Pensions: types of pension scheme: qualifying non-UK pension schemes (QNUPS)

A qualifying non-UK pension scheme (QNUPS) is entitled to the same exclusions from Inheritance Tax as a registered pension scheme (IHTM17035) but they will not necessarily provide similar pension benefits or be structured in a similar way.

A QNUPS is defined in IHTA1984/S271A as a pension scheme that is not a registered pension scheme but is established in a country or territory outside the UK and meets the requirements of Regulations made by the Commissioners for HMRC (The Inheritance Tax (Qualifying Non-UK Pension Schemes) Regulations 2010 (SI 2010 No. 51)).

The regulations specify that a QNUPS must, in the country in which it is established, satisfy certain regulatory requirements and be tax-recognised. If the country of establishment has no system of regulation or tax recognition, or the scheme is established by an international organisation, the scheme must provide for 70% of the member’s funds to be paid out as a pension income for life.

Although the regulations were laid in 2010 they apply retrospectively from 6 April 2006.

Any question over the status of a non-UK pension scheme as a QNUPS should be referred to Technical.