"Luxury" Tax on the Way For QROPS Pensions

The taxman is drawing up new rules to stop QROPSindirect investment in taxable property - for instance
pension holders from investing in homes, holiday homesbuying a yacht that the scheme member sails triggers
and expensive art, antiques and wine for their ownan unauthorised payment under the QROPS rules and
use.is a direct investment. However, if the QROPS owned
Taxable property--like residential property, timesharesshares in another investment vehicle that purchased
and investments in jewellery, classic cars and yachtsthe yacht for the QROPS, this would also become an
among other things--are frowned on by the taxman tounauthorised payment.
stop QROPS pension holders from benefiting from taxIf you were planning to purchase taxable property
breaks on homes or belongings that they enjoythrough a QROPS directly or indirectly, then best
themselves.advice would be to hold off the transaction until HMRC
New rules regarding taxable property for UK residentclears up what the new rules will be and when they
SIPP, SaSS and personal pension plan owners areare likely to apply from.
already in place, and the taxman has promised someIf you already hold this sort of property in a Qualifying
special provisions are on the way coveringRecognised Overseas Pension Scheme, then consult
- Investment regulated pension scheme's which areyour independent financial advisor about whether to
non-UK resident, and hold interests in taxable propertymake a tax-effective disposal or sit tight with the
- these are QROPS (Qualifying Recognised Overseasinvestment.
Pension Schemes) or non-UK SIPP schemes.How the rules work
- Scheme members who use their offshore pension toThe taxman's thinking behind the taxable property rules
buy taxable propertyin the UK is that pension scheme members should not
"These provisions will be set out in regulations to bebe able to buy luxuries for their own use with cash
published in due course," said a HM revenue andthat has attracted tax relief as a pension contribution.
Customs spokesman. "Until then, we cannot commentIt follows that if HMRC feel cash from a former UK
on what they might be."pension fund that also attracted tax relief is used by a
No date is set for the introduction of the new rules.QROPS member to buy similar luxuries, then that
Calculating the tax penaltypurchase should be subject to tax as if the money
The regulations for UK pension schemes makewere in a UK scheme.
acquiring taxable property an unauthorised paymentThe problem comes from pinning down what part of a
that triggers a tax charge on the scheme member andQROPS fund derives from a UK pension transfer and
a sanction charge on the scheme administrator.what is a new contribution. In other unauthorised
These charges are taxed at 40% of the unauthorisedwithdrawal scenarios, HMRC has stated that the UK
payment plus a surcharge of up to 15%.fund would be treated as the first part of the purchase
If the taxable property is a home or timeshare, the taxcash.
is the annual rent received, if this is over 10% of theFor instance if you transferred £50,000 in to a
property value or 10% of the property value if it is less.Qualifying Recognised Overseas Pension Scheme and
Capital gains tax is also charged on disposal of taxablesubsequently topped up the fund with £30,000
property, but this is expected not to figure in penaltiesthat had not received UK tax relief, then bough a
for non-UK residents, who are not liable for CGT.classic car for £35,000, all that money would be
Indirect investments are also taxedconsidered an unauthorised withdrawal even though
The rules are also expected to cover direct andyou has the £30k to 'cover' most of the price.