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UK Pension Transfers for Expats

QROPS explained: rules, charges, and how to decide in 2026.

A QROPS (Qualifying Recognised Overseas Pension Scheme) can allow UK pension holders living permanently abroad to transfer their pension out of the UK tax wrapper. The rules changed significantly in October 2024. This guide covers what you need to know before speaking with a regulated specialist.

Informational only, not financial advice. QROPS transfers of defined benefit pensions above £30,000 require regulated advice.

Last reviewed: July 2026

In short

A QROPS (Qualifying Recognised Overseas Pension Scheme) is an overseas pension scheme that has met HMRC requirements, allowing UK pension holders permanently resident abroad to transfer their pension assets out of the UK tax wrapper. HMRC publishes a list of qualifying schemes (the ROPS list). Once transferred, the pension is administered under the host country rules, and HMRC retains a reporting interest for ten years. A 25% Overseas Transfer Charge applies unless specific exclusion conditions are met. Following the Autumn Budget 2024, the EEA and Gibraltar exclusion was removed from 30 October 2024, meaning the same-country residence condition is now the primary practical exclusion for most expats. An Overseas Transfer Allowance of £1,073,100 was introduced in April 2024, capping the amount that can be transferred OTC-free. QROPS is rarely suitable for US persons and is not appropriate for everyone.

Definition

A QROPS, or Qualifying Recognised Overseas Pension Scheme, is an overseas pension scheme that has met HM Revenue and Customs requirements, allowing UK pension holders permanently resident abroad to transfer their UK pension assets out of the UK tax wrapper and into the overseas scheme. HMRC uses the term ROPS (Recognised Overseas Pension Scheme) on its published list; the "Q" (Qualifying) prefix refers to schemes that also satisfy the additional conditions needed to receive a UK pension transfer.

Once transferred, the pension is administered under the host country rules. HMRC retains a reporting interest for ten years post-transfer. A 25% Overseas Transfer Charge (OTC) applies unless one of the current exclusion conditions is met. A new Overseas Transfer Allowance (OTA) of £1,073,100, introduced on 6 April 2024, caps the total value of QROPS transfers that can be made without triggering an additional OTC on the excess.

This is a general explanation. QROPS suitability is highly individual. Nothing on this page constitutes financial, tax, or legal advice.

Eligibility

QROPS is not appropriate for everyone. Whether it is worth exploring depends on your residency, pension type, destination country, and long-term plans. These are general indicators, not a suitability assessment. The HMRC ROPS list sets out which schemes have notified HMRC of their qualifying status; appearing on the list does not guarantee suitability for your individual circumstances.

Permanently resident abroad

QROPS is primarily designed for those who have left the UK permanently or on a long-term basis. The same-country residence rule means you generally need to be resident in the country where the QROPS is registered to avoid the 25% OTC.

UK pension, overseas life

Individuals with deferred UK defined benefit or defined contribution pensions who now live and plan to retire abroad may find a QROPS simplifies cross-border administration and eliminates the currency mismatch a GBP SIPP creates.

Currency and local tax match

Where your expected retirement income and expenses are in a non-GBP currency, a QROPS denominated in that currency can remove ongoing currency risk. Local tax treatment of drawdown is a key factor a regulated specialist will model.

Not US persons (usually)

US citizens and green card holders face significant additional complexity with QROPS due to IRS foreign trust classification and PFIC rules. For most US persons, a SIPP is the more appropriate structure. Specialist US-UK cross-border advice is essential.

Long-term non-UK resident

Those who have been non-UK resident for a sustained period and have no firm plans to return are more likely to find a QROPS structure worth exploring. Returning to the UK within five years of a transfer can trigger the OTC retrospectively.

Regulated advice is required

Defined benefit pension transfers above £30,000 require regulated financial advice by UK law before a transfer can proceed, regardless of where you live. Pharos Introductions can connect you with a regulated specialist who holds the necessary cross-border permissions.

Overseas Transfer Charge

The OTC is a 25% HMRC tax charge applied at source to QROPS transfers that do not meet an exclusion condition. It was introduced in 2017. At the Autumn Budget 2024, the Government removed the exclusion for transfers to QROPS established in the EEA and Gibraltar, with effect from 30 October 2024 (per HMRC PTM102300). The remaining exclusion conditions are:

  • Same-country residence

    The member is resident in the same country as the country where the QROPS is established at the time of transfer. For example, a member living in Malta transferring to a Malta QROPS. This is the most commonly applicable exclusion.

  • Occupational pension scheme

    The QROPS is an occupational pension scheme and the member is an employee of a sponsoring employer under that scheme at the time of transfer.

  • Overseas public service scheme

    The QROPS is a scheme equivalent to a UK public service pension scheme and the member is employed at the time of transfer by an employer that participates in the scheme.

  • International organisation scheme

    The QROPS is established by an international organisation for the benefit of its former employees.

  • Retrospective charge (five-year rule)

    Even if a transfer was initially OTC-free, moving to a different country within five years can trigger the OTC retrospectively. HMRC can apply the charge if you no longer meet the exclusion condition that applied at transfer. Country selection at transfer time is therefore critical.

  • October 2024 change: what it means in practice

    Before 30 October 2024, a UK expat living in France could transfer to a Malta QROPS without the OTC, because both Malta and France are EEA countries. That EEA exclusion no longer exists. From 30 October 2024, an expat living in France who transfers to a Malta QROPS will generally face the 25% OTC unless one of the remaining exclusion conditions applies. Only a same-country transfer (French resident to a French QROPS, for instance) or an occupational or public service scheme transfer would avoid the charge. Transfers requested before 30 October 2024 and completed before 30 April 2025 could still use the now-removed EEA exclusion.

    The OTC can be refunded by HMRC in some circumstances, for example if you satisfy the relevant exclusion condition after the event, but the process is complex. A regulated specialist will model OTC exposure as part of any QROPS suitability assessment. For the full technical conditions see HMRC's Overseas Transfer Charge guidance.

    Overseas Transfer Allowance

    When the Lifetime Allowance (LTA) was abolished on 6 April 2024 under the Finance Act 2024, a new Overseas Transfer Allowance (OTA) was introduced specifically for QROPS transfers. The OTA sets a limit on the total value of QROPS transfers that can be made without triggering an additional Overseas Transfer Charge on the excess.

    OTA limit: £1,073,100

    The OTA is equal to an individual's lump sum and death benefit allowance, set at £1,073,100. This is the same figure as the former LTA. If the total value of your QROPS transfers exceeds your available OTA, the excess is subject to the 25% OTC even if a residency exclusion would otherwise apply. Per HMRC guidance on the abolition of the Lifetime Allowance.

    Impact of previous LTA usage

    Your available OTA is reduced by 100% of any LTA you used before 6 April 2024. If you crystallised significant pension benefits before LTA abolition, your available OTA may be materially reduced, limiting how much you can transfer OTC-free. A regulated specialist will calculate your remaining OTA before any transfer proceeds.

    Why this matters for larger pensions

    For most expats with modest pension pots, the £1,073,100 OTA is not a binding constraint. For those with larger pension funds or multiple schemes, staying within the OTA limit is an important planning consideration. Transfers across multiple tranches each use up OTA.

    Interaction with the OTC

    The OTA operates as a second gate alongside the exclusion conditions. A transfer must both meet an exclusion condition (same-country residence etc.) and stay within available OTA to be fully OTC-free. If either gate is missed, the 25% charge or the excess charge applies.

    OTA figures are based on HMRC guidance current as of July 2026. The OTA amount is set by statute and may change in future Budgets. Always verify with a regulated specialist before any transfer.

    Comparison

    Neither structure is universally superior. The right choice depends on your jurisdiction, tax position, currency, long-term plans, and whether the April 2027 pension-IHT change is relevant to your situation. This table is a factual summary, not a recommendation.

    FactorSIPPQROPS
    Registered inUnited KingdomOverseas (country-specific)
    UK tax wrapperYes, HMRC rules applyNo, host country rules apply
    OTC charge riskNone25% if exclusion conditions not met
    OTA limit appliesNoYes, £1,073,100 cap on OTC-free transfers
    April 2027 pension-IHTIn scope from April 2027Not in scope (overseas scheme)
    US persons suitabilityGenerally yes (treaty)Rarely suitable (PFIC / foreign trust)
    CurrencyGBPHost country currency (or multi)
    Regulated advice requiredDB > £30k: yesDB > £30k: yes
    HMRC reporting windowOngoing10 years post-transfer
    Drawdown age (2026)From age 57 (from 2028)Varies by scheme and jurisdiction
    Local tax on drawdownUK income tax (for most)Host country income tax rules
    Portugal-based schemeAvailable optionNo Portuguese QROPS on ROPS list

    This comparison is illustrative and simplified. Tax rules, drawdown ages, OTA limits, and scheme terms vary. It is not financial advice. Rules current as of July 2026.

    Situations commonly considered

    These are general situations where one structure or the other is more commonly considered, not a guide to what suits your circumstances. A regulated specialist will assess your situation in full.

    Situations where QROPS is often considered

    • +Permanent emigrant to a country where a QROPS is available on the HMRC ROPS list and the same-country residence rule is met, avoiding the OTC.
    • +Long-term residents in Malta, Gibraltar, Guernsey, Isle of Man, Australia, New Zealand, or Hong Kong, where QROPS provision exists and the same-country rule can be satisfied.
    • +Those who want pension assets denominated in local currency to match retirement spending and eliminate ongoing currency conversion.
    • +Larger pension holders (below the £1,073,100 OTA) who have taken regulated specialist advice and whose host-country tax treatment of QROPS drawdown is materially more favourable than UK income tax on a SIPP.
    • +Those for whom the April 2027 UK pension-IHT change (undrawn pension pots within UK schemes subject to IHT from April 2027 under the Finance Act 2026) makes retaining a large SIPP estate less attractive, and for whom the host-country succession rules on a QROPS are preferable.

    Situations where a SIPP is often the practical route

    • -US citizens and green card holders, for whom IRS foreign trust classification and PFIC exposure make most QROPS structures unsuitable. The US-UK tax treaty provides specific recognition for SIPPs that it does not extend to most QROPS schemes.
    • -Those resident in France, Spain, or another EEA country, where the removal of the EEA exclusion from 30 October 2024 means a Malta or Gibraltar QROPS would attract the 25% OTC unless a same-country scheme exists (there is currently no QROPS on the HMRC ROPS list for France or Spain).
    • -Those who may return to the UK within five years, for whom the retrospective OTC risk and the re-entry tax complications of an overseas pension make a SIPP the simpler structure.
    • -Portugal-based expats: HMRC's current ROPS list includes no Portuguese schemes, making a SIPP (or International SIPP) the standard route for UK expats in Portugal.
    • -Those with modest pension values where a SIPP already provides adequate flexibility and the cost and complexity of a QROPS transfer outweighs any structural benefit.

    April 2027 Pension-IHT Change

    The Finance Act 2026 is law. From April 2027, undrawn pension funds held within UK-registered pension schemes, including SIPPs, will fall within the scope of inheritance tax. This is a confirmed change, not a proposal.

    What changes for SIPP holders

    From April 2027, the value of an undrawn SIPP held on death will typically form part of the deceased's estate for IHT purposes. Depending on total estate value, this could result in up to 40% IHT on the remaining pension pot, applied after personal allowances.

    QROPS are not UK-registered schemes

    Once a UK pension has been transferred to a QROPS, it is no longer a UK-registered pension scheme. The April 2027 UK IHT rules apply to UK-registered schemes, not to QROPS funds. However, this does not mean QROPS are IHT-free: the host country's succession and estate tax rules will apply instead, and these vary significantly by jurisdiction.

    This is one factor, not a standalone reason

    The April 2027 change is a material planning consideration but not a standalone reason to transfer to a QROPS. Transferring to avoid the UK IHT change while incurring the 25% OTC would rarely be beneficial. A regulated specialist will weigh the IHT change alongside OTC exposure, local succession taxes, drawdown tax treatment, currency, and your personal circumstances.

    Model your pension IHT exposure

    Our pension-IHT projection tool lets you model the potential inheritance tax on an undrawn pension under the April 2027 rules. It does not give advice, but it makes the liability visible before you speak with a specialist.

    Open pension-IHT projection tool

    How we help

    Pharos Introductions is not a financial adviser and does not give QROPS advice. What we do is connect you with regulated specialists who hold the necessary permissions for cross-border pension advice in your jurisdiction, and who understand the specific OTC, OTA, and local tax rules of your country of residence.

    Because Pharos introduces rather than advises, we are not tied to any QROPS provider or jurisdiction. The regulated specialist we match you with recommends what fits your circumstances, and that recommendation is theirs, not ours.

    You share your situation

    Tell us your location, pension type, and what you need. Short form. No advice given.

    We review and match

    Every submission is read by a human. We identify a regulated specialist with QROPS expertise in your jurisdiction, with the right permissions for cross-border pension advice.

    Your introduction

    We connect you directly. No auto-forwarding, no pressure. The regulated advice conversation happens on your terms.

    QROPS or SIPP

    Choosing between keeping a UK pension and transferring to a QROPS depends on individual circumstancesA diagram showing that an existing UK pension can either be kept in the UK, for example in a SIPP, or transferred overseas to a QROPS. The two routes are drawn as equal, mirror-image options because neither is inherently better. The same set of factors informs either route: the likelihood of returning to the UK, ongoing UK earnings or ties, certainty of long-term residence, the size of the pension pot, the currency you will spend in, and whether defined benefit (safeguarded) benefits are involved. A regulated specialist weighs these against your circumstances. A transfer of safeguarded benefits worth more than thirty thousand pounds requires regulated advice by law.Your existing UK pensionKeep it in the UKfor example a SIPPTransfer overseasa QROPSthe choicedepends on:What a regulated specialist weighs, the same factors for either routeLikelihood of returning to the UKCertainty of long-term residenceOngoing UK earnings or tiesThe currency you will spend inSize of the pension potWhether DB (safeguarded) benefits applyNeither route is inherently better.
    Keeping a UK pension and transferring to a QROPS are not better or worse in the abstract: the right route depends on individual circumstances. A transfer of safeguarded (defined benefit) pension worth more than £30,000 requires regulated advice by law. Pharos introduces you to a regulated specialist and does not advise.

    Questions

    What is a QROPS and how does it work?

    A QROPS (Qualifying Recognised Overseas Pension Scheme) is an overseas pension scheme that has met HMRC requirements, allowing UK pension holders living permanently abroad to transfer their pension assets out of the UK tax wrapper and into the overseas scheme. HMRC publishes a list of schemes that have notified it of their qualifying status (called the ROPS list). Once transferred, the pension is administered under the host country rules, and HMRC retains a reporting interest for ten years post-transfer. A 25% Overseas Transfer Charge can apply if the transfer does not meet one of the current exclusion conditions.

    Who is eligible to transfer their UK pension to a QROPS?

    Eligibility depends on both your personal circumstances and the specific QROPS you are considering. Generally, you must be permanently resident outside the UK at the time of transfer. Not all QROPS schemes accept all nationalities or residents. A Malta-based QROPS, for example, may have different eligibility rules to an Australian superannuation scheme that meets the QROPS criteria. Regulated advice is required for any defined benefit pension transfer above £30,000, regardless of your country of residence.

    What is the Overseas Transfer Charge and when does it apply?

    The Overseas Transfer Charge (OTC) is a 25% HMRC tax charge applied to QROPS transfers that do not meet an exclusion condition. It was introduced in 2017. Following the Autumn Budget 2024, the EEA and Gibraltar exclusion was removed with effect from 30 October 2024. The remaining exclusions are: (1) the member is resident in the same country as the QROPS at the time of transfer; (2) the QROPS is an occupational pension scheme and the member is an employee of the sponsoring employer; (3) the QROPS is an overseas public service scheme and the member is employed by a participating employer; or (4) the QROPS is established by an international organisation for its former employees. A retrospective charge can also apply if you move country within five years of a transfer that was initially OTC-free. Per HMRC guidance at gov.uk/guidance/overseas-transfer-charge.

    What is the Overseas Transfer Allowance (OTA) and how does it affect QROPS transfers?

    The Overseas Transfer Allowance (OTA) was introduced on 6 April 2024 when the Lifetime Allowance (LTA) was abolished. It sets a limit of £1,073,100 (equal to the former LTA) on the total value of QROPS transfers that can be made without triggering an additional Overseas Transfer Charge on the excess. If your total transfers to QROPS exceed your available OTA, the excess is subject to the 25% OTC regardless of whether a residency exclusion applies. Your available OTA is reduced by 100% of any LTA you used before 6 April 2024. Per HMRC guidance on the abolition of the Lifetime Allowance.

    What is the difference between a QROPS and a SIPP for expats?

    A SIPP (Self-Invested Personal Pension) is a UK-registered pension scheme and remains subject to UK pension rules, including HMRC reporting requirements and UK income tax on drawdown for some recipients. A QROPS is an overseas scheme; once transferred, it is typically administered under the rules of the host country. For some long-term non-UK residents a QROPS may offer a simpler cross-border structure; for others, particularly US persons or those who may return to the UK, a SIPP is usually more appropriate. The right choice depends on individual circumstances, which a regulated specialist can assess.

    How does the April 2027 pension-IHT change affect QROPS transfer decisions?

    Under the Finance Act 2026, UK-registered pension funds will fall within the scope of inheritance tax from April 2027. This applies to undrawn pension pots held within UK-registered schemes, including SIPPs. Once a pension has been transferred to a QROPS, it is no longer a UK-registered pension, so the April 2027 IHT rules will not apply to the transferred fund directly. However, local succession and estate taxes in the host country will govern what happens to QROPS funds on death, and these can be as or more complex than UK IHT. This distinction is one factor a regulated specialist will consider when assessing whether a transfer is suitable. You can model the potential UK IHT exposure on an undrawn pension using our pension-IHT projection tool at /tools/pension-iht-projection.

    Can US citizens or green card holders use a QROPS?

    QROPS transfers are rarely suitable for US citizens or permanent residents (green card holders). The IRS typically classifies QROPS as foreign trusts rather than pension plans, and the investments held within a QROPS are frequently subject to Passive Foreign Investment Company (PFIC) rules. PFIC classification can result in punitive tax treatment on gains and income. The US Treasury and IRS have also identified certain Maltese pension transactions as listed transactions subject to enhanced scrutiny. For most US persons, retaining the UK pension in a SIPP is the more appropriate approach, as the US-UK tax treaty provides specific recognition for UK SIPPs. Specialist cross-border US-UK tax advice is essential before any decision is made.

    Is my scheme on the HMRC ROPS list?

    HMRC publishes and regularly updates a list of schemes that have notified it of their status as Recognised Overseas Pension Schemes (ROPS). The list is available at gov.uk/government/publications/qualifying-recognised-overseas-pension-schemes-qrops. Schemes can be added or removed at any time if they no longer meet HMRC requirements. Appearing on the ROPS list does not guarantee suitability for your circumstances; it simply means the scheme has met the qualifying criteria. A regulated specialist will confirm current list status and suitability as part of any transfer assessment.

    How do I choose a QROPS provider?

    Choosing a QROPS provider involves assessing the jurisdiction of the scheme, the investment options it offers, charges, currency denomination, how it interacts with local tax rules in your country of residence, and whether the provider is financially stable and well-regulated in its home country. Because Pharos introduces rather than advises, we are not tied to any QROPS provider or jurisdiction. The regulated specialist we match you with will recommend a scheme based on your specific circumstances, and that recommendation is theirs, not ours.

    Do I legally need regulated financial advice to transfer to a QROPS?

    Yes, if your defined benefit pension (or safeguarded benefits) has a transfer value above £30,000, UK law requires you to take regulated financial advice from a regulated specialist before the transfer can proceed. This applies even if you are resident abroad. Pharos Introductions can introduce you to a regulated specialist who can provide that advice; we do not provide it ourselves. For defined contribution pensions without safeguarded benefits the regulated advice requirement does not apply, but specialist input remains strongly advisable given the complexity of QROPS rules.

    Which countries have HMRC-recognised QROPS schemes?

    HMRC publishes a list of QROPS schemes that have notified it of their qualifying status. Countries with significant QROPS provision include Malta, Gibraltar, Guernsey, Isle of Man, New Zealand, Hong Kong, and Australia (via superannuation). Since the removal of the EEA and Gibraltar exclusion from the Overseas Transfer Charge in October 2024, transferring to a Malta or Gibraltar QROPS while resident in a different country will generally attract the 25% OTC unless you are resident in Malta or Gibraltar respectively. The availability, suitability, and cost of QROPS schemes varies significantly by country. A regulated adviser will confirm the current status and suitability of any specific scheme.

    More questions? Visit our full FAQ or read our guide to finding an expat financial adviser.

    QROPS suitability depends on your personal circumstances, jurisdiction, and pension type. The OTC and OTA rules make specialist input essential before any transfer proceeds. We introduce you to the right regulated specialist: no auto-forwarding, no obligation, human review.