I have a UK pension and would like to transfer it to Ireland

Depending upon the source of your UK pension, it may be possible to bring it to Ireland. Most private sector schemes will allow a transfer overseas but since April 2015, most public sector schemes cannot because they are not funded. To see if you can transfer your pension, simply contact your UK pension provider.

If you are allowed to transfer your pension benefits, you need to invest in a Qualifying Recognised Overseas Pension Scheme [QROPS]. QROPS is a pension product that has been registered with Her Majesty’s Revenue and Customs [HMRC] and can accept pension transfers from the UK without the potential for triggering a UK tax charge

Before transferring my UK pension, what should I consider?

A lot of the differences between Ireland and the UK have been harmonised recently under the UK’s new pension flexibility rules but, their continue to be areas where one jurisdiction may be more beneficial to you than the other. Most people will opt to transfer purely for convenience, administrative ease and the certainty offered by a local provider whose investments are denominated in euro.

There are a number of key points you should consider, such as:

What kind of UK pension is it and does it benefit from the new UK pension flexibility?

Your options in the UK depend on the type of scheme you are in – Defined Benefit Schemes do not benefit from the new flexible retirement rules but Defined Contribution do where the provider has changed the scheme rules to allow it. You should check with your UK provider whether flexibility is available and if not, an Irish pension may be more suitable.

What are the inheritance implication if I keep the pension in the UK?                                                                                                                                                                                            

A paid up Defined Benefit scheme will only provide a pension for a dependent – there is no lump sum death benefit entitlement.

Defined Contribution schemes can offer both a lump sum option on death and an inherited pension pot that the beneficiary can draw on. It is important to note that to be offered both options, a beneficiary needs to be nominated by you. If a beneficiary isn’t nominated and isn’t a dependent, they can only be offered a lump sum option. Your pension will not be liable to UK Inheritance Tax.

What is my pension ‘pot’ when comparing the UK Lifetime Allowance with the Irish Standard Fund Threshold?                                                                                                        

If you transfer your pension to Ireland using a QROPS, your transfer is tested against the UK Lifetime Allowance. If your fund is higher than this, you may have an immediate exposure to UK tax. Any tax due would be deducted before the transfer is made. The current Standard Fund Threshold in Ireland is €2 million. Any transfer you bring home eats into this figure, for example, if you brought home a fund of €100,000, then your remaining fund threshold in Ireland would reduce to €1.9 million.

When I want to take my benefits, what should I consider?                                                                                                                                                                                                                    

A UK pension should only transfer to an overseas scheme that has been registered with HMRC as a QROPS. Transfers to any other kind of scheme can result in penal tax changes up to 70% of the amount transferred. In certain circumstances, the QROPS provider is obliged to notify HMRC of payments made from the QROPS. These are payments made as a result of retirement; transfer to another pension policy and Death.

The following circumstances might affect you when taking your benefits from your QROPS:

  • Residency – If you have been resident in the UK  in the current UK tax year or in any of the previous five tax years [6 April – 5 April] you may be liable to UK tax on your payment. When you are making a claim on your policy, you will have to sign a declaration confirming how long you have been out of the UK. If your period of non-residence potentially exposes you to a UK tax charge, your QROPS provider will notify you of this before processing your claim.
  • Pension Age – Minimum retirement age is 55. You cannot take benefits before age 55 except in the case of ill-health. This complies with the HMRC  Pension Age test which was introduced in April 2015.
  • Reporting to HMRC – If a payment is made within 10 years of the start date of your QROPS, the QROPS provider must report the transaction to the HMRC within 90 days. There are no UK tax consequences associated with this obligation unless you fail the residency test.

WARNING

  • Transferring a pension from the UK to Ireland is not suitable for everyone.
  • Laws and tax rules may change in the future*
  • The Approved Retirement Fund [ARF] option might not be available to you at retirement.
  • Your personal circumstances also have an impact on tax treatment.
  • You should not base any decision on the information here and strongly advise you to get financial advice

*The information here is based on our understanding of the situation in October 2015.