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.