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We have recently just finished providing tax advice to a client who holds his money in a former QROPS (Qualifying Recognised Overseas Pension Scheme) held in Guernsey (this was ‘de-listed) as part of HMRC’s action against the jurisdiction a few years ago. The advance provided a review of his current options around his Relevant Non-UK scheme (RNUKS).
Essentially, one applies a statutory fiction created by Schedule 34 of FA 2004, which means that one pretends that the RNUKS is a UK registered pension scheme. Accordingly, if the transfer is one which would be permitted by a registered scheme then it is considered to be permitted for the RNUKS. Therefore, a transfer may be made by a RNUKS to either a UK registered scheme or a QROPS.