When I review this list, I have one major, niggling concern: where has all the expertise necessary to manage all these thousands of QROP schemes surfaced from, in such a relatively short time, across the globe?
Take Australia, for example, with its nigh on 1,100 active schemes, accounting for most of the first 18 pages of the HMRC list. Some would say the unlisted schemes there could add another 18 pages.
Then there’s Ireland, with nearly 700 schemes, accounting for more than 11 pdf pages on the HMRC website, notwithstanding that the cash-strapped Irish government is looking to increase its tax on pensions.
The numbers are startling because – as any competent, client-facing adviser recognises – knowing how to advise correctly on QROPS, and how to set them up, requires qualifications and years of experience, for it is far more than just a matter of number-crunching and pension-commencement lump sums.
For starters, there’s your client to consider, and his or her current and future plans, thoughts and wishes.
So… behind the almost 3,000 schemes on the HMRC list must, surely, lie a veritable global army of administrators, technicians and other experts, trained up to the gills in all manner of specialised aspects of tax, immigration law, pension planning and so on.
Let us hope so. And let us hope that all these providers and advisers, with scarcely six years of experience, at best, have absorbed the goings-on in Singapore, Guernsey, Cyprus and New Zealand sufficiently well to know, now, where some of the danger areas lie – and thus, what they should be looking out for going forward, for their clients’ benefit.
Personally, I’m not so sure how many have.
I have deep misgivings about the way some QROP schemes have been sold by some advisers, and the schemes that are being offered; and I know I’m not alone.
Many people believe HMRC is also concerned, and that it cannot and will not remain silent for much longer. Its first priority is the welfare of the honest British taxpayer, after all, not the QROPS-providing industry.
Lately, noises out of Australia suggest that the “technical understanding” there of what constitutes a “pension in payment” could be at odds with the UK interpretation.
If this difference is confirmed and similar issues turn out to be widespread among jurisdictions, it seems possible, if not likely, that rather less paper and ink may be required to print out HMRC’s QROPS lists at some point in the future.
Perhaps I am wrong, though. Perhaps it is true that large numbers of people with no previous experience in multi-jurisdictional pension transfers have, in fact, become experts overnight.
Me? I suspect the time may not be all that far off now, when the powers that be will come looking to prise open that great big, increasingly curious QROPS box, in order to peer inside, and to see, once and for all, exactly what lurks within.