If you live in Ireland but have a British pension or investment now is a good time to review them and consider whether or not to transfer your UK pension to Ireland. As with everything there are pros and cons but the benefits will depend on the type of pension you have.
Most of the differences between UK and Irish pensions have been harmonised. However, there are some areas in which one jurisdiction may be more beneficial to you than the other. You may choose to transfer your UK pension to Ireland for convenience and administrative ease, but before you make that decision it’s important to talk to a financial adviser first. Most UK private sector pensions may be transferred overseas but most public sector schemes may not.
Pros & Cons of transferring your pension to Ireland
- Transferring your UK pension to Ireland is certainly more convenient and easier to manage. You have access to local financial advisers who can advise you and help administer your fund, in euros.
- If you transfer your pension to Ireland, your transfer value is tested against the UK lifetime allowance of £1m. If your pension fund is higher than this, there may be an immediate exposure to UK tax. This would be deducted before the transfer is made.
- It also allows for a greater level of flexibility as to how and when you can access your pension.
- If you keep your pension in the UK, a paid-up Defined Benefit pension won’t provide a death benefit entitlement. It will only provide a pension for a dependent in the event of your premature death. If you transfer it to Ireland, the transfer value or value of the pension on the date of death is payable to your estate. Your pension won’t be liable to British inheritance tax.
- In Ireland, you can access 25% of your fund as tax-free cash up to a maximum of € 200,000-lifetime limit, per person. However, if your tax-free lump sum exceeds €200,000 then the excess will be taxed whereas it could be paid to you tax-free in Britain.
- If you have been living in the UK for the past 10 years prior to the current tax year, you may be liable for UK tax on your transfer payment to Ireland. If you withdraw from your Qualifying Recognised Overseas Pension Schemes (QROPS) within the first 5 years of the transfer, the transfer will be subject to British tax rules.
- You can transfer most private-sector pensions but most public sector pensions cannot be transferred.
To avoid triggering a UK tax charge when you transfer your pension to Ireland, you:
- need to be a tax resident in Ireland for 10 years prior to accessing your pension benefits.
- must not require access to your benefits for 5 years after the transfer has been completed as funds have to remain in the Qualifying Recognised Overseas Pension Schemes (QROPS) for 5 years before retirement or a transfer payment can be made.
- intend on remaining a tax resident in Ireland for 5 years after you have accessed your benefits. For this reason, you should transfer your pension sooner rather than later!
To transfer a pension from the UK:
- Advise your UK Pension Provider that you are considering transferring your UK pension to a Qualifying Recognised Overseas Pension Schemes (QROPS) in Ireland. Inform them that you require the current transfer value and all the relevant discharge forms. Once completed, send them back to your financial adviser.
- Once this information has been received by your financial adviser they will recommend the best course of action and guide you through the application process.
- The application is then submitted to your chosen provider by your financial adviser on your behalf.
- Once received, your policy will be converted into Euro and your new Irish policy will be set up.
- If your UK pension is a defined benefit pension a UK financial adviser will need to be involved.
Retirement options once you’re transferred your UK Pension to Ireland
On retirement, you can take a 25% cash lump sum and with the balance (subject to Revenue rules) you can:
- Buy a guaranteed pension income for life (an annuity)
- Invest in an ARF /AMRF Fund
- Drawdown the entire fund as taxable cash
- Choose a combination of these options.
If you qualify for an ARF, the following is a breakdown of some of the reasons why you might transfer your UK pension to Ireland:
- Death Benefits – The tax process in Ireland is more favourable compared with the UK where death taxes can be up to 73%. You should seek tax advice relevant to your own inheritance circumstances to ensure you’re availing of all relevant tax reliefs
- Convenience – Easier to have your pension administered in Ireland when you live here. Provides for more flexible access to the fund. You can choose how and when you want to access your retirement fund
- Reduced Currency Risk – Reduces the risk of future volatility in currency rates on your pension with Brexit looming in the UK
- Once a transfer is made to an Irish approved product, clients can access their fund (25% Tax-Free with the balance invested into an AMRF/ARF/Annuity) once the individual:
- is age 55 or over
- has ceased being a UK tax resident for at least 10 UK tax years
- Your transferred fund will not be taken into account in the calculation of your ROI €2m standard fund inheritance
We strongly recommend getting impartial financial advice if you are thinking of transferring your UK pension to Ireland.
NB – Laws and tax rules may change in the future. Any changes to legislation or Revenue practice may result in some options not being available to you at retirement. Transferring a pension from the UK to Ireland may not be suitable for everyone. This will depend on individual circumstances, also not every UK Pension Scheme will permit such a transfer. We recommend that you get financial advice to discuss your options. Click here to request a call.
The Information herein is not advice and should not be relied upon to make investment decisions. It is provided for general information purposes only. It does not fully take into account individual financial circumstances, investment needs, and objectives, attitude to risk, liquidity needs, capital security needs, capacity for loss, etc. The tax treatment contained herein is based on O’Leary Financial Planning’s understanding of current Revenue practice as at January 2019 and on the individual circumstances of each client. This may be subject to change in the future.