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Retire without Borders Webinar
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Okay,
good to go. Okay, welcome everyone. Uh
my name is Nolo Liry and uh you're
joining us for our latest uh global
client webinar. Um today we're going to
cover a few different topics,
specifically pension related. We're
going to talk about UK pensions, uh
Dutch pensions, and uh of great interest
to me uh will be Irish pensions. In case
my name doesn't give it away or my
accent or my green tie, uh I am one of
what three million Irish current
passport holders who no longer live in
Ireland. Um uh so firstly, Kade of Falia
to any of our Irish people on board here
today, which uh for those you don't
speak Irish means uh 100,000 welcomes.
So in Ireland, we don't just give you a
a little welcome, we give you a 100,000
welcomes. Um, for me as an Irish
expatriate, uh, I guess like a lot of
us, when I left my home country, I would
move myself, my family, uh, my bank
accounts, my assets, the family pets.
Uh, one thing that we typically have all
left behind in Ireland is our pensions.
Um, I, like I'm sure everyone on this
uh, screen today, I'm proud of being
Irish. Uh, however, uh, I'm not always
convinced in our government's ability to
manage themselves. uh never mind to uh
have oversight of our pensions. A few
recent examples uh which are interesting
to see uh of our government. Uh recently
they spent €336,000
of taxpayer money on a bicycle shed. Um
not any extravagant bicycle shed. It can
hold I think 30 bikes. So that's over
€10,000 a bike cover. Um they very
recently as well they decided that the
government, this is very true, bought
themselves a new printer. Um, you think
that would be quite an easy thing for a
government to do. They forgot to measure
the building the printer was going in.
So, they had to knock down the building
on the walls at the cost of a couple of
million euros. Um, and then even better
was our wonderful e voting machines. We
spent 54 million on. Uh, spent 3.2
million to store them, never used them,
and sold them for €7,000 for scrap. So,
um I'm not too sure that that's the kind
of government that I want to have
oversight of my pension. Uh as a company
globally, one of the things that we're
most renowned for is
building crossber solutions for our
clients to help them on their financial
journey through life. Uh and thankfully
for us today uh with me here we have our
owner and our CEO uh Nigel Green who is
not just a renowned industry leader but
actually one of the things he's probably
best at is looking at regulatory
frameworks around the world and then
sourcing building and implementing
structures that our clients can use
across the globe to help them navigate
their financial world. So what we're
going to do, we're going to hand over to
Nigel who's going to talk us through uh
our pensions and the solutions and then
at the end we'll have a Q&A and I'm
hoping at very least he will solve a
problem for 3 million Irish uh
pensioners around the world.
Okay, thank you. Thank you everybody and
a big welcome from me. H I think
pensions is one of those subjects that
you know people often don't want to talk
about but you actually think about it.
It's probably your second biggest asset.
Your home's normally your biggest asset.
Second is usually your pension. Um, and
yet, I don't know, maybe it's like going
to the dentist or something. People
don't tend to look at their their
pension. And yet, in reality, it's
really really important that people look
at it. Not just review it, but review
the location of the pension. So, I'm
going to talk about that. I'm going to
talk about retiring without borders. Um,
if you think about it, you're born in a
country, you live in a country, where
you're going to end up. All of those
things uh are uh certainly things that
come into consideration when you're
doing crossber advice. So for us as a
company, you can have somebody like null
that was born in Ireland, worked in
Ireland, end up with an Irish pension
and I know right now he's in the UAE. Is
it sensible to leave his pension in
Ireland? Okay. Well, I can tell you the
conclusion already before we get to the
end of the the webinar. there are
solutions and you can safely move it to
a better jurisdiction which is going to
massively reduce your tax liability. So
okay that in mind and even if you
actually end up in in Ireland now okay
so whatever happens it would actually
all right give you a lower tax liability
so that's quite exciting uh there have
been some changes recently which affect
the Brits h so I'm going to be today
talking about what you can do if you've
left a pension in Ireland and obviously
that doesn't mean you're Irish because
you could have worked for Microsoft
could have worked for LinkedIn Intel any
of those companies your nationality
could be diverse doesn't matter it's an
Irish Irish pension. H you could have
had a pension in the UK. You could be
Italian. You could be Irish. Uh or you
could have a a pension in in Holland. In
fact, I was talking to a client recently
who actually managed to get all three.
Uh so just imagine if you worked in
those different countries, okay, you got
three different jurisdictions, those
pensions can be safely and correctly
moved to a different jurisdiction and
potentially get higher returns and okay,
much lower tax. So okay, listen on in.
I'm going to try and make it uh clear.
Obviously, it is a little bit complex
when you're dealing with crossber
advice, but nevertheless, I'm going to
do my very very best. And at the end,
null will help me and I'll try and
answer any questions that I can. And
obviously, we've got advisors around the
world that you can sit down with and
they will uh go into more detail with
you. So if I can just first of all share
some slides which are just let me all
right help me at least to go through and
just present to everybody and just kind
of explain exactly all right where we
are and okay what sort of things you can
actually do okay so very very simply
okay you know people do move so if you
actually look at the world today then
you'll see that in the world today you
you you got 40 million people in the
last 12 months have moved countries okay
that's crazy So 40 million people chose
to. So I know the UK stats for example,
500,000 people chose to leave the UK
last year. So a little bit like Ireland,
you know, there'll be different reasons
why people go and work somewhere else in
the world, but 40 million around the
world chose to work in a different
country. Okay? Well, you leave your
pension behind. Guess what? That may not
be the best advice for you. And and
people don't look at it. Why don't they
look at it? Okay. Well, there's a number
of reasons why we don't consider it.
Okay? One is perhaps it seems boring.
Uh, I'll look at it later. I'll come
back to it. Or, you know, it's small.
Okay. In the UK, there's 31 billion.
Okay. 31 billion sterling in unclaimed
pensions. Okay. Super crazy. And I'm
sure Ireland's got it share. Holland,
I'm sure, has got each share where
people have sort of worked for a
company. They've moved on. Like, it's in
unclaimed pension pots. Super crazy. But
people actually forget about their
pension. Okay. One of the services that
we do as a company is we locate and make
sure that you know where the valuations
are and then obviously we give you
advice to see whether it's useful to you
to move it to a different jurisdiction.
Okay. You always think someone's
managing it. Okay. Well, the reality is
that often pensions um are just there
and they may be growing with inflation,
but often the growth is very very low.
You can't sort it out later on when you
get to retirement. Maybe too late
certainly from a tax point of view.
Okay. And the sooner you do something
about it, okay, obviously the better. It
really can cost a lot of money. Okay.
It's not neutral. So don't think, you
know, it's uh you leave it where it is.
Okay. Well, it's actually a negative if
you don't do something about your
pension. Okay. So, let's look at what
the problems are first of all, and then
we'll go to the solutions. First of all,
you got a currency mismatch potentially.
So, if you leave your pension, let's
say, in in Ireland or in the UK, and
then you're somewhere else in the world.
Okay. Well, when it's getting out,
potentially you've got a currency lag.
Even if you're only paying 1% and banks
will often charge you more. Okay. Well,
that could cost you 20% of the value of
your pension just by the fact that your
pension isn't in the currency that you
are retiring in. Let alone the
difference if the currency moves against
you because you got it in sterling and
sterling goes down. Okay, that would
actually be a another cost on top. Okay,
if you leave your money in Ireland,
null, then uh guess what gets taxed at
source. So you got a pension in Ireland,
you've got 40%, you've got social tax,
and you could have another four on top.
Could be 54% tax taken out of your
pension before you receive it. So I just
took a figure here of someone 25,000 a
year pension, so a lower rate, 35% tax
average on that. uh taking their pension
at 55 and then that pension going up by
5% each year. Okay. The cost of that
person in tax by not moving it is €400,000.
€400,000.
Okay. Sis Sterling there. I actually
meant to put euros in there. Okay,
that's crazy. But that's what it would
cost if you left the pension in Ireland
and you're in a jurisdiction where there
was either no tax, which there's plenty
of them, or a lower rate of tax. And it
gets worse because if you uh something
happens to you, you leave it to your
children. Okay? Well, you end up with a
tax bill. So, you not only got the tax
that you have actually paid to the
government over that period, but on top
of that, then there's another 100,000
goes in what we call inheritance tax
termed differently in Ireland. Okay? You
can have underperforming funds. Uh so,
the Dutch ones in particular, they tend
to be very ultraconservative. all of
their pension schemes. We'll come to it
in a second. But just being in the wrong
funds, okay, you can imagine over a 10
15 year period, you could lose 50% of
your pension just by not being in a fund
that can actually accumulate and grow
for you. Okay? And obviously, if you've
got the wrong structure again, that adds
to the potential problems that you have
with taking tax-free lump sums, etc.
Okay? I just put it to you. I know it
sounds boring, pensions, but the reality
is it's something that people need to
look at. It's like imagine you left a
house and in in the country that you'd
left and if you didn't pay attention to
it. I mean, you wouldn't go 10 years
leaving a house behind in another
country and not having anybody check it.
Okay, that's why people need to make
sure that they actually have their
pensions checked on a regular basis and
look at what the alternatives are. Okay,
the good news if we can start with that
is European law guarantees freedom of
movement. So it's really really
fundamental to the principles of Europe
that you can go and work in another
country. Okay, you've got all the
various different countries in Europe.
Okay, if you're European, you can move.
Okay, but also fundamental to the
European law is freedom of movement of
capital. Okay, it's very very very
important. uh actually there's also in
there protection of that money. Okay. So
in fact what happened after the second
world war number of countries not only
Europe but also including many countries
around the world they put in laws that
protected people's capital. As part of
that Europe when it was formed put in
freedom of movement and protection of
that capital. Okay. The Dutch until very
recently it went to the highest court in
Europe wouldn't allow people to move
their pensions. Okay, European court
highest level said no the Dutch
companies cannot stop people moving
their pensions. Okay, it's a fundamental
human right that people are allowed to
move their pensions. Of course, the UK
now is outside of Europe, so there has
been some changes there. However, now uh
with UK legislation, you can move it to
a company pension. Okay? So, think okay
company pension and I'll explain that in
a second. But in the UK and it's law,
the law states that if you're working
somewhere abroad, you're allowed to move
it to a company pension. Okay? So,
European law, nice and simple. If you've
got a company scheme, you're allowed to
move it to another company pension.
Okay? So, that gives some massive,
massive advantages to people because why
leave it in a country that has got high
rates of tax particularly if you're not
living in that country. Okay? And like
crazy as may seem, there's actually
advantages even if you do live in
Ireland to move in the pension. And
indeed, if you're in Holland, again,
there's advantages. And from a tax point
of view, okay, but because the returns
can be higher. Okay. So why transfer?
Okay. Well, first of all, UK pensions
consolidation. You might have worked for
several companies. Bringing those
pensions together, that has a massive
advantage. If you're living abroad, tax
optimization. And if you're living
abroad, okay, now as a uh Brit, if
you've lived a abroad for more than 10
years, and 10 years is a key number
here, and your assets are outside of the
UK, no inheritance tax. Okay, so think
if you're a Brit, okay, 10 years is the
big figure. Okay, it is again for the
Dutch pensions and in fact lots of
different European figures, but once
you're out of 10 years, you're outside
of everything. Okay, now some people
will say, well, that's five years. Uh
but the reality is it says reporting
okay after 5 years 10 years you're out
the system. So always think 10 years
you're out the system. Okay when you're
out the system okay there is no tax. It
gives you other advantages but if you
leave your assets there okay guess what
or whatever those assets add up to okay
there could be an inheritance tax bill
for your children. I mean, who wants to
leave? Okay, the government, whichever
government it is, lots of money the All
right, why? Okay, well, as Null says,
are they going to use it properly?
Probably not. Okay, leave it to your
children. Leave it to the people you
want to. Okay, don't leave your children
a tax bill. Okay, Irish pensions, uh,
why would you do it? So, if you're a
Brit, you'd definitely do it because
it's it's better from a tax point of
view if you're living abroad and for
inheritance tax, okay? as well as as as
consolidation. If you're going to end up
in the UK, you might just move to a SIP,
okay, with uh those rules. But if you're
going to be outside of it or possibly be
outside of it, okay, then I would
suggest better to look at moving it.
Okay, Irish pensions is even bigger.
Okay, why? Well, nice and simple. If
your pension is in Ireland, okay, the
first thing is that you have a 25%
tax or taxfree lump sum only up to
200,000 and then after that, okay, then
even the lump sum is taxed. Okay, in
Ireland, you're forced to buy what is
called a earth or an annuity. So, let me
explain that to you. If you had a
pension fund, okay, in Ireland, when you
get to 61, you have to take an income
and the income is taxed at source. So
you could be a Brit, okay, you worked in
Ireland perhaps for LinkedIn or
something or Apple, you accumulated some
money. Okay, if you leave it there and
you get to 61, you don't have a choice.
Okay, you have to take an earth which is
just drawing income from the pension has
to be 4% at 61 and then goes to 6% and
you can't change it once you're retired
okay and you've taken the earth that's
it. If you take an annuity that gives
you a guaranteed income but the money
dies in other words once the annuity
stops the money goes to the annuity
provider. Okay? Whereas if you take a
pension and it's you're drawing the fund
out, then when you die, the fund can go
to who you want to. If it's in a company
scheme in Malta, there's no inheritance
tax in Malta. So for Irish, okay, nice
and simple. First reason, even if you're
in Ireland, you'd move it. Why? Okay.
Well, you're not forced to buy an
annuity or a earth. Okay. Lastly, no tax
of source in there. Okay, which is which
is crazy, right? So, you know, null, for
example, is in uh in the UAE at the
moment. It'd be paying tax and then
trying to claim some of that back. Okay,
that's tough. That's complicated. You
don't want to be doing that. Okay, Dutch
pensions is slightly different. Uh Dutch
pensions, they are uh in uh government
bonds, okay, or uh what America would
call treasury bills. So all the pensions
are in these very very conservative
bonds which are making 3%
peranom. So the money's in the funds and
Dutch pensions is actually the biggest
pensions in Europe. They're all in
guilts. So they're all in uh treasuries
which are only growing. Okay. Well, we
know from an investment point of view
that having some money in treasuries or
in government fixed interest, that's
fine. But if you're going to get growth
on it, you actually need to have some
exposure to other assets. So for the
Dutch, if anyone's got a Dutch pension
will tell you it just doesn't grow.
Okay. Well, by moving it, you got the
opportunity to actually have that money
put into investment funds which are very
very robust. European rules are strict.
You need diversification.
You need particular type of funds which
are extremely robust. And you're likely
instead of making 3% our average uh
performance would have been 8% on a
balance and even higher on a growth
portfolio over 12% perom. So you can
imagine over a period of time the
massive difference that makes. If you
have a Dutch pension you're forced to
buy an annuity. So you don't have a
choice. Okay annuity is you get paid an
income. Super conservative. Something
happens to you. Okay. that money gets
lost. You move it to a multi pension.
Okay, guess what? Okay, all of a sudden
you're in a situation whereby after 10
years if you're living abroad, you would
have tax advantages. Okay, and on top of
that, all right, you're in a position
where you don't have to buy that
annuity. So, you've got growth and
potential tax advantages if you're
outside of the 10 years. Okay, other
countries you can do it from. Sweden,
Belgium, bit more complex, more
paperwork. German tough, okay, but can
be moved. Okay, they can't stop it, but
there's more paperwork needed to be able
to move it. Luxembourg pensions, they
may be eligible, okay? Well, they are
eligible. There's just lots of paperwork
to do. And it's company pensions to a
company pension. Okay, which is the same
for the Brits. They need to move to a
company pension. Irish pensions. Okay.
Uh you can move to a company pension.
The only slight difference to the Irish
is they can be their own company. So
they can declare themselves as
self-employed. Only the Irish, okay? So
rather than actually have a sponsoring
company, okay, that starts the pension.
I'll come back to it in just a second.
Okay, they can actually be self employed
with a company pension. Come back to it
in a second. Okay. So, what's the
advantages? Kind of flipped through
those as I went through. Okay, we would
move a pension to ITC. ITC is a massive
uh pension provider. It's the largest
independent trust pension provider in
Ireland. They also have uh Malta
Pensions very regulated. So, what does
that mean? They have to do daily
reporting. Okay, super regulated means
it's very robust. We can only use
certain funds. So, we have to stick with
that. Okay, that's nice in so many in so
much as you're going to get nice steady
growth. Okay, you're unlikely to do
higher than the percentages I've made,
but you know, you've got a very very
robust ESG friendly portfolio. Okay, so
recap fast. 25% all right, for Brits,
they move it to Malta. If they're over
10 years, they can go to 30. Okay. If
they're within the 10 years, 25% the 25%
stays. Ireland 25% they're moving to
Malta. Okay. They don't have to do the
10 years. Okay. They can take 30%
tax-free if the pension is in Malta.
Okay. Taxed in. If you leave it in
England, if you move it to Malta, then
as long as Malta's got a tax treaty, the
tax is based on the country that you're
in. So let me explain that UAE is
taxfree. Okay, you know you live in
Malaysia. Give you a different example.
They only they don't tax foreign income.
Okay, so that would be tax-free. Uh so
you have to think what country. H you
could have two tax uh you can have two
places that you're resident. So just
think for example I'm resident in
Maitius. I'm resident in UAE. I'm
resident in Malta. you could choose
which of those you are using. So just
think when we're talking about
residency, you might want to talk to an
advisor, but you choose the right uh
residency. Okay? And for some countries,
you need to stay less than 183 days to
give you that tax-free advantage. Okay?
So think Malaysia, foreign income, tax
advantage. Okay? Let's go Maitius. Okay?
then as long as you're below 183 days in
Maitius, you only pay tax on what you
take in to Maitius. So, it does get a
little bit complicated. You need to look
at different countries, okay? But I
would suggest you particularly on
Ireland, uh reality is whatever country
you're in, I can see you're not going to
get taxed as much as you would in
Ireland. Okay? So, reality is you're
better off moving that pension. Even if
you live in Ireland, you're better off
moving that pension. Okay, Dutch, you're
probably over there not just for tax if
it's over 10, but because the growth is
super all right, low. Okay, if you're in
the UK, inheritance tax mentioned it.
Ireland's got inheritance tax, too.
Okay, forced to neutral we've already
mentioned. Okay, the great advantage
with all right, Malta is they don't tax
it as long as they got a tax treaty.
It's the country that you're living in.
Okay, and there's no inheritance tax.
Okay, so how does it work? uh you need
to set up or you need to have a company.
So if you're a client and you you know
let's say you're working for Barclays,
you could be okay well you're employed
by Barclays. Okay. Well, you need
another company. Okay. To so you have a
company that maybe you're a consultant
for that company. Could be your own
company. Obviously it's better if that's
already set up but if it's not you can
set up a company. That company then is
your sponsor. Okay. Only exception is
the Irish. They allow the Irish to be
self-employed to set up a company
pension. Okay? Reason for that is that
self-employment in Ireland is the same
as it is in Malta. Okay? You're allowed
to set up a company company pension as a
self-employed person. In the UK, you're
not allowed to set up a company pension
as a self-employed person. You're only
allowed a personal pension. Okay? Dutch
is the same. Okay? So, it's only the
Irish that can actually set up a company
pension as a self-employed person. So
okay, wherever your pension is, you
either if you're Irish, okay, you can
contribute yourself. Otherwise, it's a
company and the company has to pay into
the pension to start it. That's when
approval is €500
minimum. Okay? So the company, let's say
you've already got a consultancy
company, they start the company scheme
by putting €500
into your becomes your company pension.
Okay, company pension ITC is the
trustee. Okay, Dilla is designing the
portfolio which we can show you and we
have to check double check double check
double check and ITC compliance have to
sign it off to make sure that it's
robust. Okay. And by that I mean there's
a maximum percentage in any one usage,
maximum percentage in stock, it's got to
be ESG. there's really really strong
diversification rules which is why it
becomes very very robust but it's not
going to you know make 20% in a year
okay it's going to give you a steady
return and it isn't something you it's a
company pension you can't change it
trustees have to approve the funds okay
we because of our regulation are allowed
to design it and uh propose the uh
structures okay then they have to be
approved by the committee
And then it's a um a careful process to
give you something super super robust.
So the company pays in 500. Approval is
when that 500. Now you could move a UK
pension into your Malta IOPS company
pension. If you had an Irish pension,
you can move it in. Okay. once the 500
is paid in Dutch pension. Okay, there
may be a fight because it's recently
gone to court in Europe. So we have
lawyers but they cannot stop it. So in
other words, it will happen. It moves.
Okay, once it's into Malta, then 10
years you're out the tax system if
you're concerned about it. So I've got a
couple of questions about that. Okay,
UK, 10 years you're out. Okay, you're
Dutch, same thing. 10 years is the key
from a tax point of view. Okay, that
won't be changed, right? So, don't think
that one is going to be changed. Okay,
your funds I've already mentioned in
there. Okay, also we can allow you as a
client. So, you can have cautious,
balanced or growth. Uh you can have it
in different currencies. So we've
designed the first ones in sterling in
euros and dollar. Okay, we'll be adding
Australian dollars because people may
want to move their money from Ireland
for example to Malta being in Australian
dollars and then eventually may want to
move it to Australia into Australian
superanuation that again could people
tax advantages. Okay. So, um I think the
advantages are massive for for for
anybody to be honest. Um okay, I guess
if I'm kind of going negative, I'd go if
you're a Britain, you're going to end up
in the UK and you're sure you are. Okay.
Well, then there's no significant
advantages. Okay, you would go to a UK
SI. Okay, if you're Irish, even if
you're staying in Ireland or ending up
in Ireland, okay, there's advantages.
And if you're Dutch, massive, massive
advantages because of the growth and
you're not forced to buy an annuity.
Okay, it's massive, massive, massive for
people to look at. However, okay, I
think the one that's the one that that
that needs explaining to people is, you
know, where you going to end up and what
does that mean and what's the uh you
know, what's the potential negatives?
Okay. Uh from an Irish point of view, I
couldn't think of anywhere that taxed
you more than than Ireland. No. Um, so
if you're moving here, okay, you know,
if you're ending up somewhere tax free,
great. Okay, well, if there wasn't a tax
treaty and obviously there's 75, so you,
you know, you're pretty much covering
most countries. Uh, then you end up with
uh multitax, which is 35. Um, so kind of
like your worst case scenario if you
like if there wasn't a tax treaty, but
even that is lower than the tax that you
would pay if you left your money all
right in uh Ireland. Okay. So hopefully
n I've covered that clearly. Uh I'm sure
there's going to be all right some
questions because it is a complex
subject. Um but maybe all right we can
get people to ask questions. uh whether
that's advisers and I can see hands
raised easier if you go to the uh
question and answer or the chat okay and
ask questions because okay I got Dave
there um but difficult for me and null
to go through all the list of names and
right give you permission to speak
unfortunately but okay if you can just
write the questions in null can grab
them and I can try and explain all null
can if it's
yep well you've covered an awful lot of
territory in a very quick uh 30 minute
session. So let's kick on to some of the
questions. So first question is um how
can you set up a company pension to take
advantage of benefits if you are not
working but still some years away from retirement.
retirement.
Um so anybody can set up a company. So
uh you could set up a you know Estonia
company online. You could set up a
European company, a mult company. I mean
we could help people with that. You
could set up even a UK company. Um, I'd
rather be out of the right UK if for for
me anyway, but uh so you can set up a
company anywhere. Well, I say anywhere.
We have to do KYC. So maybe Iran's a bad
idea or something, but you can literally
have a company anywhere in the world. Uh
so you can buy an offtheshelf company.
Not difficult to do. It's not not too
expensive. Um we'd set you up a bank
account. Okay. Then uh 500 euros from
that company goes into the pension.
that's approval and then the pension is
transferred in. Like it's actually much
quicker than the UK pensions have been
in the past.
Yeah. Yeah. It's pretty seamless and it
give a vast amount of choice and often
that can be dictated on where you're
based yourself. Uh as you mentioned
earlier, I'm in the UAE so for me to do
it and I'm now actively that
surprisingly looking at moving my Irish
pension. Um I'd be looking at a company here.
here.
You have a company there but that
doesn't affect the tax. So where the
member is. Okay. Okay. So, you're the if
you move it, it's a company pension, but
you're the member. So, the benefits
don't go to the company, the benefits go
to you. If it was you and your wife, uh
the benefits are paid. So, it's two
separate pots, even though it's one
company that's the sponsor. So, you can
have one company set up. It could
actually have six people working for it.
Um and they've only got to do the 500.
That company's only need needed to start process.
process.
Sure. Uh next question. Um, would it be
good to move a pension into an IROP now
if someone is not retiring for five
years? As in, should you wait and do it
or should you do it now?
You should do it now. Um, why you got
the advantage then of being outside of
uh depends if we're talking UK or
Ireland or Holland, but ideally you want
this time thing. Um, so the longer
you're out of the system, if I can call
it that, all the countries have this
rule, and I'm going with 10 just to make
it easier. Um, if you just think 10
years, you're out. Okay, that's better
than me going. It could be five maybe
possibly. So, just think 10. So, the
sooner you've done it, okay, you're uh
no longer liable for tax based on that
that that particular pension.
Yeah. Um I mean I think it's really
important as well from a time
perspective is dependent upon the size
of the pension. If you take Ireland as
an example in Ireland you have the
concept of what's called standard fund
threshold. So once your pension goes
above€2 million euros in value anything
in excess of that gets taxed at 40%.
But when you move your pension into a
scheme such as this um it's you have a
benefit crystallization that points you
get taxed at that point and you can't
get tax on that money again. So that is
uh a very effective thing to do. So
certainly someone for a larger pension
should absolutely uh move that sooner.
Um is there any tax on transfer for UK
pensions to Malta?
No, because it's going to a company
scheme. So in the law uh it said there's
certain exemptions. So there's 25% tax.
Okay. Uh
unless it's a company pension. So, uh it
could be a personal pension or a company
pension in the UK transferred to a
company pension in Malta, no tax up to
the maximum of the lifetime allowance.
So, same thing as we got all right
there. Uh which is currently just over a
million. So, you can transfer that no
tax on the transfer. Okay. From the UK
into a multi-pension.
Sure. Okay.
If I move my Dutch pension out of the
Netherlands, would I pay more or less
inheritance tax in Malta? So, there's no
inheritance tax in Malta. So, uh you're
moving it to a jurisdiction where
there's no inheritance tax. Uh so, okay,
then it depends on where you're residing
uh when something happens to you. But
you're in Malta, Malta has no
inheritance tax. Uh so there's whereas
if you're in Holland or Ireland or the
UK there's there's a form of inheritance tax.
tax.
Yeah. Okay. Um next question is I'm just
trying to interpret uh if you're 10
years outside of the EU is it
consecutive years
or can it be six years and seven years?
Um I think this is
okay. So I mean the UK rule is five
years and after five years there's
reporting but 10 years you're out. Okay.
The Dutch says that you need to have 10
years and it's consecutive. So, um,
Ireland doesn't have this. Okay? So, if
you move it to Ireland from Ireland,
okay, you don't have this 10 year issue.
I kind of put it in there as like 10
years. It makes it easier rather than
look at each individual. Um, but maybe
maybe it's clearer to go Dutch has to be
10 years consecutive. UK, five years
after five years reporting. Um but 10 no
reporting you're out system.
Yeah. I think that just shows and
recognizes again that every pension has
its own little nuances. So it's
important to get specific advice for
yourself. Um because everyone is
slightly different. Um I have a uh
500,000 euro to invest into a pension
now I'm 51 and hope to leave Ireland in
15 years. What are my best options now?
And that's from an Irish resident.
I don't know the tax rules on uh
Ireland. You get tax benefits when you
put it into an Irish pension. Okay.
You do, but it's capped.
Okay. So, then you've got a tax benefit
put into an Irish pension. Um Okay. But
then when it's in an Irish pension, you
then want to move it to
multi pension. Okay. So, now we're
getting super complex. So if you're in
Ireland, you got a tax advantage up to a
certain amount by paying money into a
pension, but they're taxing you heavily
on the way out. So then what you'd need
to do if it's a personal pension, okay,
you actually have to move a personal
pension in Ireland to a company pension
in Ireland. Okay, and then from a
company pension in Ireland to a Malta
company pension, okay? Then you're not
taxed on the way out. So pay in while
you're there to mitigate tax. Okay. And
then before you retire, move.
Yeah. Wow.
I think that's
Yeah. I think it's important in that
context as well. If we're looking at a
500,000 uh investment and you look at 15
years growth on that, you're going to be
looking at a very sizable amount. So
then the likes of succession planning
really comes into play even if you're an
Irish resident. So um if for example
there's there's limits there's a a
capital acquisition tax is what it's
called in Ireland. So if your your
spouse would have a uh your child for
example be 310,000 anything above that
they would get taxed at 33% if it's
capital acquisitions tax. uh pension
depending upon who your inherit is uh
will be either income taxed on the year
of the member's death or uh could be
capital acquisitions tax uh depend upon
who the inherit
that's what for the rest of the audience
that's what we call inherence tax in the
UK and America's estate tax um but in in
Ireland it depends on who inherits the
money so it's different for each
individual party um but you're taxed
move it there's no tax so
so okay
okay
yeah so by moving it into the the Arabs
it becomes a lot more efficient from
that perspective. Um, okay. The 10-year
limit is that leaving the UK? I live in
Spain but still work in the UK. In Spain
there is no 25% tax-free from pensions.
Okay. So, uh, in Spain, you might be
better to, so let's say you got a
company pension, you might be better to
move it to a Malta and you need to take
personal advice. Um, but you'd move it
to a Malta pension. You'd want to be 10
years and then you would be better to
move it to a OPZ. Um, so you're actually
moving it to move it. Um, so take
personal advice, okay? uh but it's
better to move it and then move it a
second time for maximum tax advantages.
A bit like Australia, if you had an
Irish pension, you can't move an Irish
pension to Australia, but you could move
it to a Malta pension and then when the
time came right, you can move it to an
Australian pension and that gives you
tax free. Um so then it becomes
important to take tax advice, but just
think there's so much tax involved. I
mean, I know it sounds like a pain and
there's paperwork, but you know, if you
thought there was a 400,000 tax bill
just on 25 grand a year, okay, just
think it's a massive tax bill by not
doing something about it. So, taking
advice, you know, even if it's two lots
of paperwork, okay, we'll take care of
the paperwork. Um, make it easier for
you. I'm not saying, okay, there's
there's not some complexity, but it
really really is important. Just don't
leave it and end up with a great big tax
bill for for no reason. Yeah, and I
think in Spain, you know, it's a really
good example. You're going to have a lot
of people, Irish, UK, who want to retire
in Spain. And the OPEZ solution, I mean,
you're looking at Spain is a highly
taxed country. You look at uh federal
tax rates, you look at local tax rates
are pretty high. Um, and the OPEZ scheme
that you just mentioned, I mean, that
really you're looking at two to 3% uh
actual full-on income uh savings tax
rates uh if you use that structure. So,
it's highly beneficial. It's highly
beneficial, but it needs careful planning.
planning.
Yeah, agreed. Uh, Spain is popular. I
own a company in Spain. Can that company
be used to set up a multi- pension?
Yes, absolutely. Um, so that's kind of
perfect. So, the company sets up the
pension, has to put 500 in, can add if
it wants to. So, the company can add for
you and you can add if you want to. So,
there could be advantages to putting
more into the pension. That's the same
for any any any company, by the way. So
500 is the minimum to start it. That
contribution must be from the company.
So the first contribution is from the
company. After that the individual or
the company uh can invest more into it.
So obviously because there's
considerable tax advantages, you may
want to add more uh as an individual or
that company may want to add more. So
yes, absolutely. If you've got a Spanish
company, works perfectly. again a little
bit more detail on the planning uh
ultimately to see what the final
solution is.
Yeah. Uh I think this is well they're
all good questions. I like this one. Is
it possible to consolidate pensions
between husband and wife under the uh IORBs?
IORBs?
No, it isn't. Um so they have to be two
separate pots. So you can have one
company pension but there's two members.
Um, so the
the wife and the husband's money is
separated. Um, and they could obviously
draw down at different times, etc., but
they can't be joined together.
Yeah. Okay. Perfect. So, um, I
understand UK assets are under IHT in
the UK. In Spain, it's similar, but
assets elsewhere, are they just never taxed?
taxed? Okay.
Okay.
Where's Smithy? What's the inheritance?
I don't know the answer to that
question. Um, so there's no inheritance
tax in Malta, which is where your asset
is. Okay. Would that would there be a
tax applied in another country? Uh,
you'd need to take advice on it. Okay. I
don't know. But we'd look at all right
mitigation. All right. Someone's all
right. Telling me um, okay, you must be
sorry, you must be an employer of the
company. So when I said you must have a
company uh that sets up the scheme.
Okay. You also need a contract between
you. I mean it can be one page and the
company. Okay. Spain depends on location
and where the beneficiary is uh for
inheritance tax.
Yeah. Exactly. So if you're for example
Spanish if your inherity is resident in
Spain um they'll fall under Spanish uh
inheritance taxation. And of course,
you have to think, sorry, no, I'm I'm
digressing, but because I've got, if you
like, you know, I live in different
countries. Um, you know, I think people
need to realize you don't you're not
stuck. You know, you might live in Spain
most of the year, but you could actually
have a separate uh tax residence, right?
Um, so, you know, like UAE for example,
you could be tax resident there. As long
as you go there once every six months,
okay, you keep your tax residence. Um,
so just kind of think then you got a
maximum of 183 days in Spain. So you you
can actually do things to make this much
more tax efficient than perhaps people
think. So when you draw it out, it
depends on where you say your tax
residence is and you can use a tax
residence. Um, and we can obviously
carefully plan that for the person so
that it gives them maximum tax
advantages. Okay, in Europe in general
183 days is is kind of like but you
actually think you know 183 days well if
it's if you're reducing your tax
massively okay well not too difficult to
you know have part of your life in one
part and maybe part in another
potentially anyway
absolutely it's a global village uh
people are moving all the time um okay
Irish pensions dad benefits get paid
direct to beneficiaries
I have a UK will with perspective
changes in UK inheritance tax will this
still be exempt?
Uh sorry I didn't understand the
question. So your money is in pension it
goes to the beneficiary. Um I mean if
you've got a will then the will applies.
You can obviously change your will.
Yeah absolutely. Absolutely. Um okay. I
have an approved retirement fund already
in Ireland. Can I still move that and
does it make sense? I am German and live
in Germany and taxed in Germany.
Yes, it makes sense. So, if it's a
personal pension, okay, you can't you
got to move it from a personal pension
in Ireland to a company pension in
Ireland, okay, which is uh regulated
advice in Ireland, which we can we can
organize for you then a company pension.
Um, yes, it does because your tax would
be lower than it would uh by leaving it
in uh Ireland. Okay. So, yes, 100% made
sense. Yeah, it's better for tax, better
for income tax, better for succession
planning. And as you you mentioned
earlier, so when you get to 61 in
Ireland, if you have a approved
retirement fund, you got to go into
minimum of 4% draw down. And then when
you get to 71, you got to go minimum of 5%.
5%.
If you don't want income, you got to
have income and you're going to pay tax
on it. And if you're working, it's going
to add up to your your income. It's
going to give you even more income tax.
Yeah. Okay. So, a 62-year-old Irish
person living in the Netherlands, I
guess, NL with pensions in UK ah UK,
Netherlands, Canada, and Malta.
Intending to retire in France in about
five years. Should I set up my company
in or out of Europe? This could keep us
busy. Okay. Okay.
Okay.
Okay. Uh, the company doesn't make a
difference. It's probably easier in
Europe. Okay. Okay, because we can set
up a bank account easy more e easier.
Um, okay. So then, sorry, you can
transfer UK pension. Okay, transfer the
Irish the Irish pension. Um, okay. Even
France. Okay. You're going to pay less
tax than you would if you leave it uh,
okay, in um, okay, Ireland or in the UK.
All right. And France has got quite high
tax. Okay. Dutch pension you're going to
gain from growth, but you need to be 10
years outside of Holland to get the uh
so you're going to gain growth for sure
on the Dutch pension, but 10 years from
a tax point of view to be out out the
Dutch system. Yeah.
Yeah.
What's the age? 60. 62.
Okay. 62. The Dutch one I'd have to look
at. Um Okay. Because the main reason for
moving a Dutch pension is the growth.
Okay? You can't move it for tax
advantages. So there may not be an
advantage to moving the Dutch pension.
There's an advantage to moving the Irish
pension. There's an advantage to moving
the the UK pension. The Dutch pension,
you're going to be forced to buy an
annuity. Sorry, was a good question. Um,
so maybe you don't want to buy an
annuity. So there could be a reason to
transfer it uh for that, but you're not
gaining any tax advantage at 62 by
moving a Dutch pension. You don't have
enough time.
Well, unless you went to 72 and then
started drawing it.
You can't move a Dutch pension to gain a
tax advantage unless it's over 10 years. Yeah.
Yeah.
Okay. Sorry. brings up an interesting
point though, the ability to just to
confirm to people that you can have
someone who has an Irish pension, a
Dutch pension, a UK pension, and they
can consolidate them into uh ITC scheme,
which is uh a great benefit obviously.
Okay. Um
questions. Sorry, I'm probably confusing
because we've gone quite personal in
questions, but hopefully not.
Yeah, I mean uh in SP the Spanish office
are going to be busy. In Spain, you are
taxed on worldwide income. As I
understand it, it would make no
difference whether from the UK or Malta.
Okay? So, if you got a UK pension,
you're in Spain, you could end up
because the the allowance is difference
by actually paying double on the early
amount of money. If you're living in
Spain, um you got Spanish inheritance
tax, which okay, I don't know the
percentage, but maybe lower. Um okay.
And as I said previously, um, well, I
guess it's a question if you need to
spend 183 days in Spain. If you don't,
potentially you could have another
residence. Uh, and Pandora. Okay, there
you go. Um, you could you could have
something else which would give you a
tax benefit. Okay. Which may be worth
doing for minimal cost because it gives
you a tax benefit.
Yeah, I think what the question they're
referring to is it's an income basis. So
whether you draw down your pension from
the UK or from Malta and you're living
in Spain, how does that impact is it
better to draw down
double taxation treaty but the
allowances are different so you could
still end up paying more tax by leaving
it uh in the UK?
Yeah, absolutely.
And and who knows what happens in the
UK, right? You know, they could change
the rules. Um so right now in the UK you
got this problem and you probably saw it
where they borrowed money to pay debt.
Okay. All right. I mean like crazy. I
mean that's imagine you got a loan and
you use your credit card to pay a loan.
Okay, that's what the UK just did. So
the UK have to raise taxes. They've said
they won't raise income tax. Okay,
there's very few things that they um and
they've got to raise taxes. Okay, so
100% UK has to raise taxes. Okay, what
are they going to raise it on? Pensions,
capital gains tax. Okay, well if you
leave it there, I would say the odds are
they're going to increase tax on
pensions. Um, would I leave money there?
No. If I'm not going to live in there,
no chance. I wouldn't take the risk of
leaving money there, which could be more
taxed in the future because the UK's
just got to raise taxes, I'd move it to
a better jurisdiction and give myself
some flexibility. 100% for me. It's an opinion.
opinion.
Yeah, absolutely. Um, is the transfer of
a pension into Malta efficient if I'm
currently working and contributing into
the pension?
Potentially not. You'd need to talk to
an adviser because the company's
obviously contributing towards it. Um,
so okay, it may not be until um you
leave the company.
Yeah, good question.
Yeah, it is. And you may have part of
the pension for example could be defined
benefit part of it could be uh
move part of it potentially it does need
personal advice. Um so it may not be
worth moving if the company's contributing.
contributing.
Okay. Uh can I consolidate UK Irish and
Dutch? We've done that one. Okay. Um you
talk about high tax in Ireland. Is this
not just for higher rate taxpayers?
Uh you're right. There's bans. Uh but
nevertheless, you're paying the bands
all the way up to 40. But then you've
also got the social tax. Sorry. No.
What's the other tax called?
FSI, which is pay related social
insurance. And you got universal social
charge. Uh we like a few different taxes
in Ireland.
The terminology. Um so just think in
Ireland it's taxed at source, right? I
think it's the only country where they
tax a pension like income. Um okay, that
I mean that's crazy, but Ireland tax it
like income. So, it's added to, you
know, any other earnings you got, they
tax it at source. Um, okay. I mean,
that's crazy. So, if you move it, okay,
then, um, I'd say, well, everywhere I've
looked at, you pay less tax, uh, than
you would by leaving it in Ireland. Even
if you live in Ireland, you're not
forced to buy the Earth, right? So,
okay, for me, you don't have to retire
at a certain point. Um, and once you
bought the Earth, that's it. It's done.
Okay, you got no flexibility after that.
Okay, you you're taking the income. All
right. Uh there's no more options. Can't
transfer it. Can't do anything in once
you got once you're in draw down.
Yeah. And I think in Ireland from an
income tax perspective, I think it's uh
18,000. Anything that you earn below
18,000 is non-t taxable. Any uh the
standard tax rates then are 20% and then
the higher tax rates for higher income
earners. Uh that amount gets taxed.
They could change those as well, right?
But they're taxed at source. Again, why
would you leave your money somewhere
where it's taxed at source? I mean, it's
like I mean, they got the other CL said
if paying money in. Okay. Well,
Ireland's good if you're paying money
in. Okay. It's not good if you're taking
it out, which you might say is fair
enough. Um, but it's heavy heavy tax.
Okay? So, you know, I don't know about
everybody else on here, but you get
taxed so much in life. You get taxed
when you earn it, tax when you spend it,
tax when you invest it, uh, tax when you
draw your pension. Um, the same happens
to you, there's another load of tax. I
mean for me it's crazy um to be uh
particularly if you if you're able to do
it to be tax efficient I think it's just
sensible um so again it's an opinion
and and so I mean so just to answer that
it's it's not just beneficial if you're
a higher taxpayer in Ireland.
No no no
absolutely beneficial to a lower
taxpayer as well. Uh, will a Malta
pension allow me to draw funds earlier
compared to when I keep my pension in
the Netherlands?
Okay, so it's got to be 10 years. Um, so
Netherland is 10%. Okay, so you have to
reflect that if it's within the 10
years. So you can take 60%. Okay, and it
won't unless you're outside of the uh 10
years. So you have to stick with the
same uh retirement age, okay? Same rules
of 10%. So the advantage for moving a
Dutch pension is the growth because it's
all in fixed interest the the pensions.
So you're getting the advantage of that.
If you're over 10 years, you then have a
tax advantage but only if it's over 10
years. Uh so Dutch pension growth is the
advantage tax okay you're sticking and
age you're sticking with the same Dutch
rules unless you're over 10 years.
Yeah. So the next question is for
someone who who's they've had to they
said they have to leave. I think they've
got a meeting but it's a good question
and they've asked a couple of questions.
It's um um in Spain my inheritors would
be my nephews which have a big tax
percentage. So better for me the assets
to be under UK IHT as as gifts. A bit
confused about which country would
taxpayers money uh would in the UK or
Spain. I think the answer to that is we
to get in touch with Nigel and we'll put
you in touch with our dever Spanish office
office
double problem there. So we don't we
talk we talk both because the assets in
the UK so okay that means that they can
tax it. Okay there is a double taxation
treaty but we need to look at the whole
situation to understand it. Okay and
then give you professional opinion.
Yeah absolutely. Okay. Uh they're coming
thick and fast. Um, is this available to
someone who lives in Singapore or Japan
or Japanese nationals who have an Irish
or Dutch pension?
Okay, so let's finish with that one. Um,
so yes, absolutely. Uh, so you need a
company. Okay, the company sets up the
pension. Okay, that could be in
Singapore needs it needs obviously a
bank account needs to pay in 500. Um,
but the company can be anywhere in the
world. There's KYC, so anywhere
a country that's going to be approved,
right? So the company has to be in a
normal jurisdiction if that makes sense.
We can give you a list. Um yes
absolutely. Uh you're then in a multi-
pension. So then it's whether Malta has
a double taxation treaty with where
you're going to end up. So then it's
looking at right what the tax is. Okay.
Does it have a double taxation treaty? I
mentioned Malaysia just as an example
because it's one I know. No tax on
foreign income. Okay. So, we'd have to
look at the country and give you the tax
advantages, but 100% you can do it to
answer your question. Uh, and it's it's
well worth looking into. So, maybe I can
finish with that null. Um, because I
think it's the major point. Well, it's
the major point which is, you know,
because it does get technical.
It's worth looking at, getting an
analysis done, okay, understanding it,
understanding your options. Okay? then
at that stage you can make a decision.
Um, so hopefully I gave you some good
information now uh for you as an with an
Irish pension and everybody else that's
on. Okay, obviously we could go on all
day but okay there's lots of uh the
questions that may fit one individual
and it may be a totally different one
for everybody else listening. So I'm
sure that's not good for everybody. Much
better to sit down with an individual
that can look at it and will give you a
qualified opinion that's right for you
as an individual. Okay. Thank you, Nolan.
Nolan.
Yeah, absolutely fantastic. There were
so many questions there. We didn't
actually get to all of them. So, those
who we haven't got to, we'll reply
directly uh to as much as we can. We
will indeed. Okay. Thank you everybody.
Hopefully that was useful. Sorry, super
complex particularly when I got the
questions. Um but hopefully, okay, we
gave everybody that was listening a
clearer understanding of why you need to
look at a pension, why pensions are so
important. Uh and also you know always
remember is it enough um and you know
think about we talked about pensions but
it could be other assets as well. So
whilst I talked about a pension okay
don't forget when you're looking at it
as an advisor you're looking at the
pensions but you can actually looking at
other assets shares and all sorts of
other assets making it tax efficient for
you. Why pay too much tax? Okay, take a
free opinion, sit down with somebody and
look at optimizing so you have options
later on in life. Freedom is what it's
ultimately about. And freedom I means
planning, okay? Just making sure you've
got your options open to be as tax
efficient as you can. Thanks everybody.
Okay, and thank you Null for helping me
on the way through.
Okay, see you later.
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