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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