How do payments by QROPS affect the client’s tax liability in the UK?
A. A payment could give rise to a member payment charge under schedule 34 to FA 2004. In particular, the individual will be liable to an unauthorised payments charge if the payment would have been unauthorised had it been made from a UK registered pension scheme. Q. How will the HMRC determine what portion of this payment relates to the UK transfer (eg client withdrawals $1,000 cash from a $500,000 super account that consists of a UK pension transfer of $100,000)? A. Under schedule 34 to FA 2004 and SI 2006/207 a payment from a QROPS will be treated as coming first from the individual’s UK tax-relieved fund (if any) and next from the individual’s relevant transfer fund. So in the example the cash withdrawal will be treated as coming from the fund transferred from a UK scheme. There is guidance on the attribution of payments at RPSM13102190. Q. What are the tax implications, if any, when a member dies within the first 5 years of being resident in Australia Could you confirm whether this
