QROPS: still relevant, but not for most peopleA Qualifying Recognised Overseas Pension Scheme, or QROPS, is a pension scheme based outside the UK that HMRC has approved to receive transfers of UK pension funds. They were widely promoted in the expat financial advice industry for many years, sometimes appropriately, sometimes not.
British State Pensions cannot be transferred to a QROPS. Defined contribution pensions, defined benefit schemes, SIPPs, and SSASs can be. From 30 October 2024, transfers within the EEA are no longer automatically exempt from the Overseas Transfer Charge.
The Overseas Transfer Charge of 25% applies to the amount transferred above your Overseas Transfer Allowance. If your allowance is £1,073,100 and you transfer £1.2 million, the charge applies only to the £126,900 excess.
The practical reality for most expats in Thailand is that QROPS are not the default answer they once appeared to be. When QROPS funds are remitted to Thailand, they are considered taxable income regardless of the tax treatment in the QROPS jurisdiction. The lack of a Double Taxation Agreement between Thailand and most common QROPS jurisdictions, including the Isle of Man, Malta, and Gibraltar, means no tax credits are available, making the entire remitted amount fully assessable.
Most people are better keeping their UK pension where it is. A QROPS transfer has significant implications and tax charges that need to be weighed carefully before proceeding. There are situations where a transfer makes sense, but the case needs to be built from the numbers, not from a sales conversation.
The inheritance tax change coming in 2027One significant development that has not yet received the attention it deserves among expats is the forthcoming change to how pensions are treated for inheritance tax.
From 6 April 2027, most unused pension funds and death benefits will be included in the value of a person's estate for inheritance tax purposes. Currently, most unused pension wealth sits outside the estate under discretionary trust arrangements and passes to beneficiaries without triggering inheritance tax.
Unless an exemption applies, unused pension funds will be aggregated with the rest of the estate and the excess over nil-rate-band taxed at 40%. Inherited pensions may also incur income tax of up to 45% upon drawdown by the beneficiary, leading to a combined effective tax rate of 64% to 67% in some cases, or higher for large estates.
The existing exemption for pension death benefits passing to a surviving spouse or civil partner who is a long-term UK resident, or to a registered charity, will be maintained.
For expats, this does not mean pensions should automatically be drained. It means the pension now sits within a broader estate planning conversation rather than being treated as a separate vehicle that bypasses the estate entirely. The strategy that made sense before 2027 may need revisiting.
What this means in practiceFor a British expat planning retirement abroad, the pension picture involves at least five separate questions.
- Will your state pension be frozen in the country you are moving to, and have you maximised your NI record before the Class 2 option closed?
- Can your private pension provider deal with you as a non-resident, and on what terms?
- How does the tax treaty between the UK and your country of residence treat your pension income, and what does that mean for how and when you draw it?
- Is a QROPS transfer worth considering given your pension size, country of residence, and the available jurisdictions?
- Has the 2027 IHT change affected your estate planning assumptions, and is your pension now sitting in a different position within your overall plan?
None of these questions has a universal answer. The right approach depends on the size of your pension, where you are living, your wider income, your beneficiary position, and your time horizon.