This policy statement was delivered to the judge on the 12 July but as yet has not been made public. It is possible this delay could be a sign of a major shake-up in the way QROPS will be operated.

Regulation changes of this kind have occurred in the past, the most substantial of which was the removal of Guernsey as a valid QROPS jurisdiction last year causing the “de-listing” of more than 300 schemes.

Michael Brinksman, editor of Which Offshore's online offshore finance publication, expressed his concerns over HMRC's handling of the situation: “This shocking negligence has highlighted the need for greater transparency in the QROPS market and more governmental advice for those looking to move abroad.

“Too many offshore pension schemes are being sold by advisers who don't possess the expertise to be a truly reliable source of information. The judge's request for clarification and review from HMRC only serves to confirm that this lack of transparency is causing a problem for many expats.”

Here we speculate on what impact HMRC's new review may have, from the best case scenario all the way to the worst possible outcome.