Irish Pension Transfer Service – Transferring Irish Pensions to UK, Overseas for Non-Irish Residents

January 9, 2023
Russell Hammond

Russell Hammond

Chartered Financial Planner & Chartered Investment Adviser · FPFS FCSI

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Transferring Irish Pensions to the UK or Overseas for Non-Irish Residents

What You Need to Know

My Irish Pension Transfer Service helps Irish expatriates (and other individuals with Irish pension schemes) who plan to retire overseas, have accumulated Irish pensions with a value (known or estimated) above €250,000, and have a bona fide reason for wishing to transfer their Irish Pension away from Ireland*.

Transferring your Irish pension to a UK SIPP (Self-Invested Personal Pension) or a Maltese Retirement Trust (QROPS – Qualifying Recognised Overseas Pension Scheme) gives you far more flexibility with your savings. I can help you consolidate your Irish pensions into one pension scheme, allowing you to draw steady income or lump sums with far less hassle.

UK & Maltese Pensions versus Irish Pensions

While UK SIPPs and Maltese pension plans have a few key differences (see the following sections), they differ from Irish pensions in a few key ways.

The Facts About UK SIPPs

It’s important to understand how UK SIPPs operate when it comes to accessing your money, taxation, and succession planning.

Accessing Your Money at Retirement

You can access your retirement funds as soon as you reach age 55, and you can take a lump sum of up to 25% of your funds without paying UK income tax. In addition, you can withdraw money from your SIPP at any time, which helps you avoid the hassle of an Irish Approved Retirement Fund (ARF) and the Approved Minimum Retirement Fund.

Taxation on UK SIPP Products

UK SIPPs are free from capital gains tax, so you will pay no tax on any investment income generated. You also won’t face any Irish Income Tax, Universal Social Charge or PRSI on your SIPP payments or pension income. SIPP income payments are assessable to UK income tax at source, but if you live in a jurisdiction with a UK Double Taxation Agreement (DTA), you can request a ‘No Tax Code’ from the HMRC.

The Facts About Malta Retirement Trust Products

Malta Retirement Trust Products share some fundamental similarities with UK products, but differ on the age at which you can access your funds (50 for Malta products and 55 for UK SIPPs). This could be a determining factor in your decision — when do you want to start drawing your pension funds?

You’ll also notice that succession planning is much more straightforward with a Maltese fund, without the age 75 restrictions, which could be another consideration.

Accessing Your Money at Retirement

It’s easy to access your retirement benefits any time between ages 50 and 75, and you can take an initial lump sum of up to 30% of your fund (which is exempt from Maltese tax). Like a UK SIPP product, this helps you avoid the complexities of establishing an Irish Approved Retirement Fund (ARF). You can continue to draw regular income payments from your pension or take larger lump sums (if applicable).

Taxation on Malta Retirement Trust Products

Investment growth within Malta Retirement Trust products is free from Maltese tax. Just like UK SIPPs, they do not deduct Irish Income Tax, Universal Social Charge or PRSI on the pension payments, which makes it far easier than trying to reclaim your Irish Income Tax paid in Ireland. In most cases, income payments are assessable to Malta Income Tax, usually at non-resident rates.

However, in many jurisdictions, Malta has an effective Double Taxation Agreement in place. This means your pension income will only be assessable in your country of residence. Therefore, it’s essential that you seek tax advice.

Succession Planning with Maltese Pensions

Succession planning is simple with a Malta Retirement Trust product. Your remaining funds can be paid directly to your beneficiaries, and they are all exempt from Maltese Tax. They are also typically exempt from Irish Capital Acquisition Tax. However, your country of residence might charge inheritance taxes, and so local tax advice is essential.

The Benefits of Transferring to a Maltese or UK Scheme

As you can see from the information above, if you’re planning to retire abroad, it makes sense to transfer your pension away from your Irish scheme to a more versatile Maltese (QROPS) or UK scheme (SIPP).

Why Work with a Pensions Expert

It’s crucial that you enlist the services of a pensions expert to help with an Irish Pension Transfer. Not only do they understand the ins and outs of the different products, but they can also assess your specific situation and provide you with relevant advice.

Get in Touch

If you are thinking about transferring your Irish pension plan to a more versatile UK SIPP or Malta Retirement Fund product, contact me today for a fee-free initial discussion regarding the Irish Pension Transfer options available to you.

I look forward to hearing from you.

*It is important to note a transfer of Irish pension benefits overseas can only be made for bona fide purposes (e.g. no longer living in Ireland, pension consolidation etc.) and not for the purpose of circumventing Irish pension tax rules.

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Russell Hammond

Russell Hammond FPFS FCSI

Chartered Financial Planner & Chartered Investment Adviser

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