Jurisdiction Comparison Table

In order to help you understand the differences between some of the major QROPS jurisdictions, we have constructed a table below which compares some of the features applicable to an Isle of Man, Guernsey or Hong Kong based QROPS. The information relating to the Isle of Man scheme assumes such a scheme is not only a "50C Scheme" but has also been approved as a QROPS by Her Majesty's Revenue and Customs (HMRC).

	Isle of Man	Guernsey	Hong Kong
Is income drawdown available?	Yes After 5 full tax years of non UK residence, the drawdown rate is dependent upon age and assumed investment return. Income is paid gross.	Yes After 5 full years of non-UK residency benefi ts may be paid under more flexible Guernsey rules. Income is paid gross.	Yes After 5 tax years of non-UK residence, income is not subject to UK GAD rates. Income is paid gross.
What is the maximum amount of lump sum available at normal retirement age?	25% of the initial transfer value where the client has been non UK resident for less than fi ve years. After 5 years of non UK residence the maximum lump sum available is 100% of fund value at retirement less 70% of the transfer value when the pension was transferred in.	During fi rst 5 years of non-UK residency 25% of tax relieved funds transferred. After 5 full years of non-UK residency 30% of fund. Subject to trustee discretion.	Any payments are subject to trustee discretion.
How is the pension payable calculated?	2After 5 tax years of non-UK residence there is no minimum pension amount. Drawdown rate is dependent upon age and assumed investment return and can vary from year to year.	After 5 tax years of non-UK residence no insurance annuity required and payments made gross. More flexible Guernsey rules may apply.	After 5 tax years of non-UKresidence Actuarial tables and Modern Portfolio Theory apply.
What happens if the client dies before retirement (during first 5 years of non-UK residency)?	100% return of fund to deceased's estate/nomination with 0% tax charge or a spouse's/dependant's pension could be paid, subject to tax at applicable rates.	Balance of fund payable in accordance with member's wishes. No Guernsey tax is payable preretirement.	100% of fund by-passing Probate to dependant.
What happens if the client dies before retirement (after 5 years of non-UK residency)?	100% return of fund to deceased's estate/nomination with 0% tax charge or a spouse's/dependant's pension could be paid, subject to tax at applicable rates.	Balance of fund payable in accordance with member's wishes. No Guernsey tax is payable pre-retirement.	100% of fund by-passing Probate to dependant.
What happens if the client dies after retirement (during fi rst 5 years of non-UK residency)?	Post retirement pre 77, return of fund less 35% tax charge of residual relevant transfer fund. Post retirement post 77, return of fund less tax charge up to 55% of residual relevant transfer fund. Alternatively, in both cases, a spouse's/dependant's pension could be paid.	Post retirement pre 77, return of fund less 35% tax charge of residual relevant transfer fund. Post retirement post 77, return of fund less tax charge up to 55% of residual relevant transfer fund. Alternatively, in both cases, a spouse's/dependant's pension could be paid.	Post retirement pre 77, return of fund less 35% tax charge of residual relevant transfer fund. Post retirement post 77, return of fund less tax charge up to 55% of residual relevant transfer fund. Alternatively, in both cases, a spouse's/dependant's pension could be paid.
What happens if the client dies after retirement (after first 5 years of non-UK residency)?	A spouse/dependant's pension may be paid. No Isle of Man tax and 100% paid to whoever is nominated by the Member. Not reportable to HMRC.	A spouse/dependant's pension may be paid. No Guernsey tax and 100% paid to whoever is nominated by the Member. Not reportable to HMRC.	100% of fund by-passing Probate to dependant.
What are the tax rates on taking a pension if the client is resident in same jurisdiction as the QROPS?	Single personal allowance is GBP 9,300 (tax year 2010/2011). 10% band on income up to GBP 10,500. Balance at 20%.	20% tax.	0% tax.
What are the tax rates on taking a pension if the client is resident outside of the QROPS's jurisdiction?	No Isle of Man tax but there may be taxes in the country in which the client is resident.	No Guernsey tax but there may be taxes in the country in which client is resident.	No Hong Kong tax but there may be taxes in the country in which the client is resident