All Qualifying Recognised Overseas Pension Schemes (QROPS) schemes will have to notify HM Revenue & Customs (HMRC) of their status every five years, according to new proposals published by the tax man.
The notification rule starts from April 1, 2015 and the renotification date depends on whether a QROPS was started before or after April 1, 2010.
Post April 1, 2010 QROPS
The notification date is set five years after the date HMRC sent the scheme manager their QROPS reference number.
HMRC gives some examples in draft guidance about the new regulations:
- If the HMRC QROPS reference letter was dated April 2, 2010 the scheme manager must renotify QROPS status on: April 2, 2015, then April 2, 2020, April 2, 2025 and so on
- If the QROPS reference letter was dated June 15, 2012, the renewal deadlines are: June 15, 2017, June 15, 2022, June 15, 2027 and so on
Pre April 1, 2010 QROPS
HMRC wants these QROPS to renotify their status before the 10th anniversary of the QROPS reference letter.
A table of renotification dates was published with the draft guidance:
| Date of HMRC QROPS reference letter | First Renotification date |
|---|---|
| April 6, 2006 - May 31, 2006 | April 30, 2015 |
| June 1, 2006 - July 31, 2006 | May 31, 2015 |
| August 1, 2006 September 30, 2006 | June 30, 2015 |
| October 1, 2006 - November 30, 2006 | July 31, 2015 |
| December 1, 2006 - January 31, 2007 | August 31, 2015 |
| February 1, 2007 - March 31, 2007 | September 30, 2015 |
| April 1, 2007 May 31, 2007 | October 31, 2015 |
| June 1, 2007 - July 31, 2007 | November 30, 2015 |
| August 1, 2007 - September 30, 2007 | December 31, 2015 |
| October 1, 2007 - November 30, 2007 | January 31, 2016 |
| December 1, 2007 - January 31, 2008 | February 28, 2016 |
| February 1, 2008 - March 31, 2008 | March 31, 2016 |
| April 1, 2008 - May 31, 2008 | April 30, 2016 |
| June 1, 2008 - July 31, 2008 | May 31, 2016 |
| August 1, 2008 - September 30, 2008 | June 30, 2016 |
| October 1, 2008 - November 30, 2008 | July 31, 2016 |
| December 1, 2008 - January 31, 2009 | August 31, 2016 |
| February 1, 2009 - March 31, 2009 | September 30, 2016 |
| April 2009 1, - May 31, 2009 | October 31, 2016 |
| June 1, 2009 - July 31, 2009 | November 30, 2016 |
| August 1, 2009 - September 30, 2009 | December 31, 2015 |
| October 1, 2009 - November 30, 2009 | January 31, 2017 |
| December 1, 2009 - January 31, 2010 | February 28, 2017 |
| February 1, 2010 March 31, 2010 | March 31, 2017 |
If a QROPS fails to notify their status to HMRC, the scheme can be excluded – failing to notify includes an incomplete notification
