Is anyone aware how the Swiss tax authorities treat QROPS pension surrender income?
I transferred my UK pension pot to a QROPS scheme in Guernsey around 15 years ago
Now I have passed the age of 55, and have been resident in Switzerland for 20 years, my research tells me there is no UK tax implication upon vesting of the pension value
However, how do the Swiss tax authorities treat such pension income?
I am resident in Baselland
If they treat it like Pillar 2 or 3a, it would be a one-off pension tax rate of 4.9% on the total value if redeemed together in a single tax year
I’m interested in exiting the ongoing fees of the QROPS scheme, hence the full surrender
I’m planning to ask the Baselland tax authority directly (in dodgy German), but thanks for any pointers if any previous experience out there
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My understanding is that if this is considered equivalent to a swiss pension fund (I assume you checked because otherwise it should have been reported in your wealth 
), then in the absence of a dual taxation treaty it will be treated like a swiss pension (lump sum taxation rates).
So maybe one thing is whether you need to wait until you reach 58 (the legal early swiss retirement age).
(Guernsey doesn’t seem to have a tax treaty with Switzerland)
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Good point, thanks I hadn’t considered the CH age limit
Whilst it’s Guernsey located the QROPS is under UK rules, as I understand it
Will ask them about the CH age implications at the tax office
Guess I could still use it earlier towards the mortgage - or hoof it into a CH Pillar 2 or 1e with voluntary contribution buy-in space? But then have the 3 year access limit.
If it’s truly under uk jurisdiction wrt taxation (didn’t look like it on cursory glance), then the only tax due is on uk side, at least that’s what the treaty says.
Thanks for your comment on this.
Coming back to it, I have since received a response from the Swiss tax office endorsing what you say about the double tax treaty with UK - tax only due on the UK side.
I have always assumed, being a UK QROPS scheme, that the tax liability is between UK (origin of the pension contributions) and Switzerland (my tax residency).
I hadn’t considered the Guernsey element.
I will submit the pension redemption in my Swiss 2025 tax return, assuming the tax will be calculated on the pillar II equivalent lump sum rate.
But what about Guernsey? If this is between the Swiss and Guernsey, and there is no double tax treaty, can I avoid being taxed by both jurisdictions?
Maybe you can first move it somewhere with a tax treaty? (But yes I’d assume it’s the actual domicile of the fund that matters, not the fact that it originated in UK, if you had somehow moved it to a Swiss QPROPS scheme, I don’t think Swiss authorities would have cared about UK status).
Too late to move, the full amount has been redeemed
Looks like I will need to disclose the full surrender to both tax authorities, CH and Guernsey and hope for the best