QROPS: Section 157E Schemes Open To Non-Residents Excluded From Being Recognised Overseas Pensions.

After HMRC's announcement on 6 December 2011 of its intention to make amendments to the current legislative regime governing qualifying recognised overseas pension schemes (QROPS), a period of consultation followed.

It seems that the proposed amendments were in fact a 'fait accompli' long before the consultation period ended because, despite many representations made by various bodies, the amendments took effect from 6 April 2012 with only minor changes.

In response to the changes that came into effect on 6 April 2012, Guernsey, by way of the Income Tax (Pension Amendments) (Guernsey) Ordinance, 2012 created a new form of pension scheme, known as a 'Section 157E scheme'.

The key features of a Section 157E scheme are no Guernsey tax relief on contributions, no Guernsey tax charge on benefits received regardless of the resident status of the member, and benefits may be payable from age 55 with no upper age limit on benefit payments. It seemed that a Section 157E