On 27 November HMRC published guidance (accessible here) on transfers to  qualifying recognised overseas pension schemes ("QROPS"). For transfers  before 24 September 2008 to a scheme on the QROPS list, HMRC will not  normally raise or pursue a tax assessment of the transfer, even if it was later  determined that the scheme was not a QROPS. This easement is due to the  change in information made available by HMRC on and after 24 September  2008. The QROPS list was updated from that date to provide warnings that a  pension scheme listed may not be a QROPS. However, HMRC reserves the  right to pursue such transfers where there is evidence of dishonesty or abuse  and, in the circumstances it would not appear to be unfair to impose a tax  charge.   

The guidance provides that for transfers after 24 September 2008 date HMRC  will consider whether to exercise its powers after reviewing the individual facts  of each case and considering whether it would be fair to impose a tax charge  in the circumstances.