QROPS providers are not required to notify HRMC of any payments from transferred pensions unless the member is:
- Resident in the UK when the payment is made, or
- Although not resident in the UK at that time, has been resident in the UK earlier in the tax year in which the payment is made or in any of the ten tax years immediately preceding that tax year (the “ten year rule”) and
- For the first 10 years following the transfer
So long as any benefits taken within the “five year rule” are consistent with the benefits that could have been taken as a UK resident then no UK tax consequences arise.
There is an exception however where the QROPS has been used to invest in what is known as “taxable property” which includes for example residential property. Such schemes are subject to indefinite reporting of payments made to HMRC.