This article provides a broad over-view of how Irish Pensions Arrangements can be transferred to Overseas Arrangements.
Occupational Pension Schemes and Personal Retirement Savings Accounts (PRSA)* can be transferred to similar arrangements elsewhere in the EU under the IORPS II legislation.
*There is a tax charged on transfers pertaining to PRSA’s and it may not be in the best interest of the client. We recommend that each client takes time to ascertain, on a case by case basis, which course of action is most appropriate for their personal circumstances.
It is worth noting that Personal Retirement / Buy-Out Bonds, Personal Pensions and Approved Retirement Funds (ARFs) are landlocked and cannot be transferred to other EU states in most circumstances, although they can be transferred to the UK in some instances under QROPS (Qualifying Recognised Overseas Pension Schemes) legislation.
What is IORPS II?
This is a comprehensive EU directive that looks to harmonise the governance and management of pensions schemes across the European Union.
What are the benefits of IORP II?
- Provides better protection through enhanced governance and risk management.
- Provides clear, relevant and more consistent communication to members of pension schemes.
- Removes barriers to cross border occupational pension schemes.
- Ensures that trustees have the appropriate powers to supervise the schemes
Why would you consider an International Pension transfer?
Consideration should be given to transferring your Irish pension overseas if:
- You are no longer living in Ireland or plan to take up residency somewhere else in the future.
- You previously worked overseas and built up pension benefits which need to be consolidated.
- You are an international executive and you can fund pension benefits in other jurisdictions.
What are the Revenue’s Requirements for Overseas Pension Transfers?
The Revenue require that the transfers must be to an IORP established in an EU state.
For transfers outside of the EU, the pension holder must be a resident of the state they are transferring to and the pension structure must be similar to the Irish pension structure.
All pensions must be Bona Fide and should not be done in order to circumnavigate tax. Revenue approval will no be needed if the transfer is to an IORP but may be in other circumstances.
Where can I transfer my pension?
Where individuals meet all the criteria, we have found Malta to be a suitable jurisdiction to transfer pensions to. It has a similar legal system to Ireland and has been a player in the international transfer market.
What are the key benefits of transferring an Irish pension to Malta?
There a number of key reasons why people consider transferring their pensions to Malta:
- Access your pension at 50 if you have lived overseas for 5 years already.
- Access to a wide range of investment opportunities.
- Tax Efficient – Malta has around 70 Double Tax Treaties (DTA’s), for residents of countries that have a DTA with Malta.
- 30% tax-free lump sum available – This is higher than the current Irish and UK tax-free lump sum of 25% (Irish pensions capped at a tax-free lump sum of €200K and UK pensions capped at £250K tax-free lump sum). **
- No Tax to pay on assets within scheme (with exception of immovable property in Malta).
- Option of nominating beneficiaries on your pension.
- No Lifetime Allowance Charge.
- Inheritance benefits and the ability for you to pass on your pension pot to your beneficiary upon death Capital Acquisition Tax / Inheritance Tax free.
- You can combine various smaller pensions into one large pot resulting in only one annual management fee as well as the opportunity to benefit from the economies of scale by combining investment.
- Avoid ongoing currency exchange fees in investing in the same currency as the country you reside in or in any currency of your choice.
** The HMRC impose further restrictions on how and when the tax free lump sum can be accessed, and if these are not adhered to, an additional tax charge may apply.
How we help
We can help take the effort out of this for you by demonstrating how this would work for you and your family and providing you with one cohesive Financial Plan.