QROPS Jurisdictions

Qualifying Recognized Overseas Pension Schemes (QROPS) are not destined in every country. For example, if you live in Egypt, there are no QROPS jurisdictions there and for security, you may not want your pension transferred there anyway. You would be better off transferring your pension to Malta for example, which is an EU country which has a Double Taxation agreement with Malta meaning that the pension is paid out gross avoiding all taxes.

Choose your QROPS jurisdiction / QROPS destination below. We have listed the countries which have Double Taxation Agreements with the QROPS destination.

QROPS Isle of Man

The Isle of Man is the most popular QROPS jurisdiction for 2013. This QROPS destination allows a much higher pension INCOME to be paid out over time, so is especially popular for those who wish to access a higher level income. Especially for those that may be in poor health.

However, a 20% income tax is imposed at source in the Isle of Man, if you live in a country which DOES NOT have a Double Taxation Agreement (DTA) with the Isle of Man. The Isle of Man also has a 7.5% tax upon death which is deducted at source in the Isle of Man.

Countries which have a DTA with the Isle of Man

No. Country Where QROPS is Taxable Signed Effective Status
1 Australia Pensions only taxable in the country of residence 29 January 2009 6 April 2011 (Isle of Man) 1 July 2011 (Australia) In force
2 Bahrain Pensions only taxable in the country of residence 3 February 2011 1 January 2013 (Bahrain) 6 April 2013 (Isle of Man) In force
3 Belgium Pensions only taxable in the country of residence 16 July 2009 Awaiting ratification Not in force
4 Denmark Pensions taxable in the IOM 30 October 2007 1 January 2009 (Denmark)6 April 2009 (Isle of Man) In force
5 Estonia Pensions only taxable in the country of residence 8 May 2009 January 2010 (Estonia) 6 April 2010 (Isle of Man) In force
6 Faroe Islands Pensions taxable in the IOM 30 October 2007 1 January 2009 (Faroes) 6 April 2009 (Isle of Man) In force
7 Finland Pensions taxable in the IOM 30 October 2007 1 January 2009 (Finland) 6 April 2009 (Isle of Man) In force
8 Greenland Pensions taxable in the IOM 30 October 2007 1 January 2009 (Greenland) 6 April 2009 (Isle of Man) In force
9 Guernsey If pension earned from work in IOM = taxable in IOM otherwise taxable in country of residence(i.e. Guernsey) 24 January 2013 5 July 2013 In force
10 Iceland Pensions taxable in the IOM 30 October 2007 1 January 2009 (Iceland) 6 April 2009 (Isle of Man) In force
11 Ireland Pensions only taxable in the country of residence 24 April 2008 1 January 2009 (Ireland) 6 April 2009 (Isle of Man) In force
12 Jersey If pension earned from work in IOM = taxable in IOM otherwise taxable in country of residence (i.e.
Jersey) 24 January 2013 21 June 2013 In force
13 Luxembourg Pension taxable in IOM unless pension not related to employment in which case taxable in country of residence (i.e. Luxembourg) 8 April 2013 Awaiting ratification Not in force

Click here for more info on the Isle of Man QROPS

QROPS Gibraltar

QROPS Gibraltar has taken over as the second most popular QROPS jurisdiction for British expatriates around the world. The Gibraltar QROPS destination is the de facto solution if you do not know where you will end up retiring in the world. The Gibraltar QROPS avoids all UK taxes and taxes a flat rate of 2.5% on income at source in Gibraltar. There are no taxes upon death.

Any country can be used with a QROPS in Gibraltar, you just pay the 2.5% income tax at source. It is then up to you to report any income in the country you retire in and pay income tax in that country.

Click here for more info on a QROPS in Gibraltar

QROPS Malta

QROPS in Malta takes the no.3 QROPS jurisdiction for 2013. This popular QROPS destination is best used for British expats in Europe. Malta is an EU country and has 65 Double Taxation Agreements with countries around the world. For most of these countries, your QROPS will be paid out gross, free of tax in Malta. Although it does depend on the specific agreements.

Please note if you live in a country which DOES NOT have a DTA with Malta, you will pay tax of between 15% and 35% on any income deducted at source in Malta.

****PLEASE NOTE: The Malta QROPS Trustees will require EVIDENCE that a member is tax resident in a jurisdiction with a suitable DTA before any payment can be paid gross, otherwise tax in Malta will be deducted.*****

Malta Income Tax Rates for 2008 – 2012

Chargeable Income € Tax Rate (%) Tax Deducted (€)
0 – 700 0% 0
701 – 3100 20% 140
3101 – 7800 30% 450
7801+ 35% 840

Countries which have a DTA with Malta

Country Date Signed Where Taxable Notes
Albania 02/05/2000 Pension income taxable in Albania Article 21
Australia 09/05/1984 Pension income taxable in Australia Article 18 – Temporary residents taxed in Malta
Armenia Initialled/being negotiated
Austria 29/05/1978 Pension income taxable in Austria Article 18
Azerbaijan Initialled/being negotiated
Bahrain 06/03/2012 Pension income taxable in Bahrain Article 20
Barbados 05/12/2001 Shared Jurisdiction Article 21 – Taxable in Malta
Belgium 28/06/1974 Pension income taxable in Belgium Article 21
Bosnia-Herzegovina Initialled/being negotiated
Bulgaria 23/07/1986 Pension income Taxable in Malta Article 18
Canada 25/07/1986 Shared Jurisdiction* Article 18
China 02/02/1993 Pension income taxable in China Article 22
Croatia 21/10/1998 Pension income taxable in Croatia Article 21
Cyprus 22/10/1993 Pension income taxable in Cyprus Article 22
Czech Republic 21/06/1996 Pension income taxable in Czech Republic Article 21
Denmark 30/12/1998 Pension income taxable in Denmark Article 18
Egypt 20/02/1999 Pension income taxable in Malta Article 18
Estonia 03/05/2001 Shared Jurisdiction Article 21 – Taxable in Malta
Finland 30/10/2000 Pension income taxable in Finland Annuity Income taxable in Malta Article 18
France 29/08/2008 Pension income taxable in France Article 22
Georgia 23/10/2009 Pension income taxable in Georgia Article 21
Germany 08/03/2001 Pension income taxable in Germany Article 18
Greece 13/10/2006 Pension income taxable in Greece Article 21
Guernsey 10/3/2013 Pension income taxable in Guernsey Article 20
Hong Kong 8/11/11 Pension income taxable in Malta Article 17
Hungary 06/08/1991 Pension income taxable in Hungary Article 22
Iceland 23/09/2004 Pension income taxable in Iceland Article 21
India 08/09/1994 Shared Jurisdiction Article 23 – Taxable in Malta
Ireland 14/11/2008 Pension income taxable in Ireland Subject to Remittance limitation**
Isle of Man 23/10/2010 Pension income taxable in Isle of Man Article 21
Israel Signed – Not yet in force
Italy 16/07/1981 Pension income taxable in Italy Subject to Remittance limitation**
Jersey 19/07/2010 Pension income taxable in Jersey Article 21
Jordan 16/04/2009 Shared Jurisdiction Article 21 – Taxable in Malta
Korea 25/03/1997 Pension income taxable in Korea Article 21 – Subject to Remittance limitation**
Kuwait 24/07/2002 Pension income taxable in Kuwait Article 22
Latvia 22/05/2000 Shared Jurisdiction Article 22- Taxable in Malta
Lebanon 16/04/2010 Pension income taxable in Lebanon Article 21
Libya 28/12/2008 Pension income taxable in Libya Article 23
Lithuania 17/05/2001 Shared Jurisdiction Article 22 – Taxable in Malta
Luxembourg 29/04/1994 Pension income taxable in Luxembourg Article 21
Malaysia 03/10/1995 Pension income taxable in Malaysia Article 18
Mexico Initialled/being negotiated
Moldova Initialled/being negotiated
Montenegro 04/11/2008 Pension income taxable in Montenegro Article 21
Morocco 26/10/2001 Pension income taxable in Morocco Article 18
Netherlands 18/07/1995 Pension income taxable in the Netherlands Article 19
Norway 02/06/1975 Shared Jurisdiction* Article 18
Oman Initialled/being negotiated
Pakistan 08/10/1975 Pension income taxable in Pakistan Article 21
Palestine Signed – Not yet in force
Poland 07/01/1994 Pension income taxable in Poland Article 22
Portugal 26/01/2001 Pension income taxable in Portugal Article 21
Qatar 26/08/2010 Pension income taxable in Qatar Article 18
Romania 30/11/1995 Pension income taxable in Romania Article 23
Russia Signed – Not yet in force Being renegotiated
San Marino 10/09/2009 Pension income taxable in San Marino Article 21
Saudi Arabia Signed – Not yet in force
Serbia 16/06/2010 Pension income taxable in Serbia Article 21
Singapore 29/02/2008 Shared Jurisdiction Article 21 – Taxable in Malta
Slovakia 07/09/1999 Pension income taxable in Slovakia Article 21
Slovenia 08/10/2002 Pension income taxable in Slovenia Article 22
South Africa 16/05/1997 Shared Jurisdiction Article 18 – Taxable in Malta
Spain 08/11/2005 Pension income taxable in Spain Article 21
Sweden 09/10/1995 Pension income taxable in Sweden Article 21
Switzerland 06/07/2012 Pension income taxable in Switzerland Article 21
Syria 22/02/1999 Pension income taxable in Syria Article 21
Thailand Initialled/being negotiated
Tunisia 31/05/2000 Pension income taxable in Tunisia Article 21
Turkey Signed – Not yet in force
UAE 13/03/2006 Pension income taxable in the UAE Article 21
Ukraine Initialled/being negotiated
United Kingdom 12/05/1994 Pension income taxable in the United Kingdom Article 18 – Subject to Remittance limitation**
United States of America 10/11/2010 Pension income taxable in the USA Article 17 – Double Taxation Relief Order
Uruguay 11/3/11 Pension income taxable in Uruguay Article 20

MALTA DOUBLE TAXATION AGREEMENT DETAILS

Whilst the majority of DTAs provide for pension income to be taxed in the country of residence of the member, there are some exceptions.

1. Shared Jurisdiction*:

In the cases of shared jurisdiction these treaties give the source state (Malta) primary tax jurisdiction, with tax relief granted in the Residence State for any tax deducted in Malta. For Canada and Norway, pension income is taxable in Malta, capped at 15%, members can elect to have their pension income taxed in Canada.

2. Subject to Remittance Limitation**:

Some of the DTAs have a “remittance limitation” clause included, which requires the pension income to be remitted to a bank account in that country in order to obtain relief from tax in Malta. However this only comes into force if the country of residence only taxes pension income on a remitted basis (as opposed to a worldwide basis).

The only countries that have a remittance clause and tax on a remittance only basis are:

UK and Ireland – where payments are made to individuals resident but non domiciled in Ireland, the pension payment should be received (paid directly by the Trustee) or remitted (subsequently transferred by the beneficiary) to Ireland. Korea – where payments are made to inward expatriates that have been resident in Korea for not more than 5 years in a 10 year period the pension payment should be received (paid directly by the Trustee) or remitted (subsequently transferred by the beneficiary) to Korea.

********The Trustees will require evidence that a member is tax resident in a jurisdiction with a suitable DTA before the payment can be paid gross.***********

Please click here for more info on a pension transfer to a QROPS in Malta

QROPS New Zealand

QROPS in New Zealand have fallen out of favour as you need to use a New Zealand based discretionary fund manager which means your pension options are limited to five options based on risk. However, there is zero tax in New Zealand, it is a secure QROPS jurisdiction, has very strong pension regulations and protection. Also, you can take up to 100% of any increase in your pension pot as a lump sum. You also are not required to take a pension like you do in other districts. So, if your pension just wants to be invested conservatively and passed onto your children, there is no safer destination. Also, the fees on QROPS in New Zealand are now very low. You can set up a QROPS in New Zealand for 200 GBP set up fee and 200 GBP per year after.

List of Countries which have a DTA with New Zealand

Australia
Austria
Belgium
Canada
Chile
China
Czech Republic
Denmark
Fiji
Finland
France
Germany
Hong Kong
India
Indonesia
Ireland
Italy
Japan
Korea
Malaysia
Mexico
Netherlands
Norway
Philippines
Poland
Russia Federation
Singapore
South Africa
Spain
Sweden
Switzerland
Taiwan
Thailand
Turkey
United Arab Emirates
United Kingdom
United States of America

Click here for more info on a QROPS pension transfer to NZ

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