Transferring your UK pension to an overseas scheme may offer tax or estate-planning advantages, depending on your country of tax residence, the applicable double taxation agreement and your personal circumstances.
However, to avoid punitive UK tax charges, the pension scheme must appear on His Majesty’s Revenue and Customs (HMRC) QROPS list.
This guide explains what the QROPS list is, why it matters for UK expats, the eligibility requirements for inclusion, and how to select a suitable scheme.
What You Will Learn
- What does the QROPS list refer to, and why is it important?
- Which requirements must pension schemes fulfil to qualify for the HMRC QROPS list?
- What may cause a scheme to be removed from the QROPS HMRC list?
- How to select a compliant QROPS that matches your tax residency and retirement goals.
What Is the HMRC QROPS List?
The HMRC QROPS list is a published list of overseas pension schemes that have notified HMRC that they believe they satisfy the statutory requirements to be treated as a Qualifying Recognised Overseas Pension Scheme (QROPS) and have asked to be included on the published list.
The list, updated twice monthly, enables advisers and scheme members to verify that a pension scheme has made the necessary notification to HMRC.
However, inclusion does not constitute approval or endorsement by HMRC. It does not confirm the scheme’s ongoing compliance with QROPS rules.
Individuals should seek professional advice and conduct thorough due diligence before initiating any transfer, as failure to meet QROPS criteria can lead to severe tax consequences.
Why Is the QROPS HMRC List Important?
Transferring a UK-registered pension to an overseas scheme that is not a recognised overseas pension scheme (ROPS), or which does not satisfy the relevant QROPS requirements where applicable, can result in significant UK tax charges.
Unless specific exemption conditions are met, such transfers are typically treated as unauthorised payments, attracting a 40% tax charge — potentially rising to 55% in some cases. The scheme administrator may also be liable for a scheme sanction charge.
To avoid this, the receiving scheme must be listed on the HMRC QROPS list at the time of transfer. Since 30 October 2024, the 25% Overseas Transfer Charge (OTC) generally applies unless one of the statutory exemptions is met. In many cases, this means the QROPS is established in the same country where you are tax resident at the time of transfer. This rule replaces the previous exemption for transfers to schemes within the EEA or Gibraltar.
UK expats should therefore ensure:
- The scheme is included on the QROPS list,
- They are resident in the same jurisdiction as the QROPS at the time of transfer, and
- They continue to satisfy the conditions for any Overseas Transfer Charge exemption during the relevant five UK tax year monitoring period, where applicable.
QROPS Pension Transfer to SIPP
Reassess whether your QROPS still aligns with your long-term retirement goals. We’ll compare keeping it in Malta or Gibraltar with transferring to a UK SIPP—so you can weigh flexibility, regulation, and future value before making your next move.
What Are the QROPS Pension List Eligibility Requirements?
Before a pension scheme can appear on the HMRC QROPS list, it must first qualify as a Recognised Overseas Pension Scheme (ROPS). To achieve and maintain QROPS status, the scheme must satisfy both structural and jurisdictional requirements, and its administrator must:
- Notify HMRC that the scheme qualifies as a ROPS.
- Formally request inclusion on HMRC’s public QROPS list.
- Undertake to provide HMRC with any required information to demonstrate continued compliance.
- Notify HMRC via form APSS251B if the scheme ceases to meet the ROPS conditions.
A pension scheme cannot be both a UK-registered pension scheme and a ROPS. Additionally, it must be established in one of the following jurisdictions:
- Outside the United Kingdom.
- An EU member state, Iceland, Norway, or Liechtenstein.
- A country (excluding New Zealand) that has both a double taxation agreement with the UK and a non-discrimination clause.
- A country with a tax information exchange agreement with the UK.
To qualify as a ROPS, the scheme must also satisfy the following three tests:
- The tax recognition test.
- The regulatory requirements test.
- The pension age and benefits tax relief tests.
The Tax Recognition Test
To pass the tax recognition test, the scheme must be registered with the tax authority in its home jurisdiction and available to local residents. The country must operate a system of personal income taxation and offer tax relief either on contributions or on distributions.
The only exceptions are schemes on the Australian QROPS list, which must comply with superannuation plans.
Regulatory Requirements Test
The scheme must be regulated by a pension authority in its jurisdiction. If no such regulator exists, it may still qualify if it meets one of the following conditions:
- It is established in an EU country, Iceland, Norway, or Liechtenstein.
- It is an occupational pension scheme offered by an employer.
- It is administered by an entity authorised to manage pension schemes.
- It is administered by an entity authorised to provide pension schemes.
The Pension Age and Benefits Tax Relief Test
To be a ROPS, a pension scheme must only allow withdrawals from age 55, except in cases of early retirement due to ill health. This threshold will rise to age 57 from 6 April 2028 to align with the UK’s Normal Minimum Pension Age (NMPA) under the Finance Act 2022.
However, the following public scheme measures are exempt from this increase:
- Police
- Firefighters
- Armed forces
Members who held an unqualified right to take benefits before age 57 in a registered scheme on or before 3 November 2021 may retain a Protected Pension Age (PPA). Where the receiving QROPS is capable of preserving those rights, a Protected Pension Age may be retained through a block transfer or, in some cases, ring-fenced to the transferred funds following an individual transfer.
Early access for certain professions (such as athletes) is permitted only if this is explicitly stated in the scheme rules and consistent with UK legislation.
Where tax relief is available on contributions, it must not be offered exclusively to non-residents of the country where the scheme is based.
Note: Government-backed public service schemes are exempt from the regulatory and pension age tests if they are officially recognised or administered by the national government.
Considering Moving Your Pension Abroad?
Why Do Pension Plans Get Removed From the HMRC List of QROPS?
A pension scheme may be removed from the HMRC QROPS list for several reasons. However, due to confidentiality obligations under UK tax law, HMRC does not publicly disclose the specific rationale for each delisting.
Below are common reasons why schemes are excluded, along with their implications:
| Reason for the Removal | Explanation | Consequences |
|---|---|---|
| Status change | The scheme met the QROPS criteria at the time of initial assessment but later ceased to qualify. | Transfers made before delisting are typically treated as authorised. Post-delisting transfers may be unauthorised. |
| Incorrect notification | HMRC determines that the scheme did not meet ROPS conditions, despite notification received. | Any transfers to such a scheme are treated as unauthorised, subject to a 40% charge and potentially a 15% surcharge. |
| Failure to satisfy ongoing statutory conditions | HMRC suspects the scheme may not comply with QROPS rules or is being misused. | The scheme may be temporarily removed pending review. If confirmed non-compliant, it will be permanently delisted. |
Important: Inclusion on the QROPS list does not guarantee ongoing compliance. It is the responsibility of individuals and their advisers to verify scheme status at the date of transfer and monitor ongoing compliance thereafter.
To mitigate these risks, speak to a qualified cross-border pension specialist. At Titan Wealth International, our advisers conduct a full technical review of your existing QROPS, including fee structures and investment suitability. Where appropriate, we recommend alternative schemes that better align with your residency, retirement objectives, and the latest HMRC criteria.
What Are the Benefits of Choosing a Scheme From the QROPS Approved List?
Maintaining your pension within a scheme listed on HMRC’s QROPS register can offer significant tax advantages, provided you meet the relevant conditions at the time of transfer.
These benefits can help UK expats preserve and enhance their retirement wealth. Key benefits include:
- Inheritance tax exemption.
- Overseas transfer allowance.
- Pension commencement lump sum.
- Double taxation agreement.
Inheritance Tax Exemption
Until 6 April 2027, unused pension funds held in a QROPS are typically not considered part of a UK estate for Inheritance Tax (IHT) purposes. This allows pension assets to pass to beneficiaries after your death without incurring UK IHT.
However, from 6 April 2027, under the provisions of the Finance Bill 2025-26, most unused pension funds and pension death benefits (including those held in QROPS and QNUPS) will fall within the deceased member’s estate for IHT purposes. Consequently, they will be added to the taxable estate and taxed at 40% above the available nil-rate bands.
Personal representatives (not scheme administrators) will be responsible for reporting and paying IHT. They may issue a withholding notice directing pension scheme administrators to withhold up to 50% of taxable benefits for up to 15 months from the end of the month of death.
Not all benefits fall within the IHT scope, though. Death-in-service benefits paid from registered schemes are excluded, and existing exemptions are preserved for assets passing to:
- A surviving spouse (where they are a long-term UK resident)
- A surviving civil partner (where they are a long-term UK resident)
- A registered charity
For HNW UK expats, overall IHT exposure is now also contingent upon long-term resident (LTR) status under the residence-based IHT regime introduced on 6 April 2025. An LTR is an individual who has been a UK tax-resident for at least ten of the previous 20 tax years.
An individual who is no longer treated as a long-term UK resident may fall outside the UK residence-based IHT regime for non-UK assets, depending on how the legislation applies to their circumstances.
While local inheritance rules may still apply depending on the jurisdiction, jurisdictions such as Malta may offer estate-planning advantages for some individuals, depending on local succession law, tax rules and personal circumstances.
Given the changes, individuals considering or holding a QROPS for IHT mitigation should reassess their long-term strategy alongside their LTR position and the timing of beneficiary nominations.
Overseas Transfer Allowance
The Overseas Transfer Allowance (OTA), along with the Lump Sum Allowance (LSA) and the Lump Sum and Death Benefit Allowance (LSDBA), replaced the Lifetime Allowance from 6 April 2024. These allowances cap the amount you can transfer or withdraw from a UK pension scheme, including QROPS, without triggering UK tax charges.
- OTA: Set at £1,073,100 (subject to any available transitional protections), the Overseas Transfer Allowance limits the amount that can be transferred to a QROPS before an Overseas Transfer Charge may arise under the allowance rules. Whether the charge ultimately applies also depends on the statutory Overseas Transfer Charge exemptions.
- LSA: Capped at £268,275 (25% of the OTA), the LSA is the amount you can withdraw as a pension commencement lump sum free of UK tax.
- LSDBA: Also set at £1,073,100, the LSDBA defines the amount that can be paid out tax-free to beneficiaries on death. Any excess is taxed at the beneficiary’s marginal rate.
Note: The OTC exemption only applies if your QROPS is based in your country of residence at the time of transfer. If you move within five years post-transfer, the exemption may be reassessed—emphasising the need for ongoing compliance checks.
Pension Commencement Lump Sum
The Pension Commencement Lump Sum (PCLS) refers to the portion of your pension fund that can be withdrawn tax-free, typically from age 55.
If your pension is held within a Qualifying Recognised Overseas Pension Scheme (QROPS) listed by HMRC, you may be eligible to withdraw a tax-free lump sum of up to 25% of your fund—subject to the Lump Sum Allowance (LSA) limit of £268,275.
Some jurisdictions may permit up to 30% to be withdrawn tax-free; however, the UK tax benefit only applies to 25% of the first £1,073,100, in line with the new allowances introduced following the abolition of the Lifetime Allowance.
Amounts above the available Lump Sum Allowance may become subject to UK tax, although the final tax treatment depends on UK legislation, your country of tax residence and any applicable double taxation agreement.
It is essential to review both UK and local tax implications before making any withdrawals.
Double Taxation Agreement
The UK tax treatment of QROPS withdrawals depends on UK domestic legislation together with any applicable double taxation agreement between the UK and your country of tax residence. Conversely, UK tax residents are typically liable for UK income tax on pension income including withdrawals from a QROPS.
This can result in the risk of double taxation if the pension is also taxed in the jurisdiction where the QROPS is held.
However, if the UK has a double taxation agreement (DTA) with your QROPS country, you can avoid being taxed twice on the same income. Double taxation agreements are designed to prevent the same income being taxed twice. How relief is given depends on the wording of the relevant treaty, and taxing rights vary between countries.
The UK has DTAs with many jurisdictions that host approved QROPS, including:
Before transferring or drawing funds, it is advisable to consult a financial adviser with cross-border expertise to interpret the relevant DTA and its application to your specific tax residency.
QROPS may also offer other planning advantages, such as access to broader investment options (e.g., ETFs, bonds), currency flexibility, and greater flexibility in managing currency exposure through multi-currency investment and withdrawal options, where available.
Get Your Complimentary QROPS Pension Review as a UK Expat
In just 15 minutes with Titan Wealth International’s cross-border pension experts, you will:
- Understand whether your current QROPS remains tax-efficient and compliant.
- Discover if your scheme aligns with the latest HMRC rules and your residency status.
- Explore restructuring options to reduce fees and enhance investment performance.
International SIPP vs QROPS: A Decision Framework for UK Expats in 2026
International SIPP (Self-Invested Personal Pension) is not a separate pension scheme, but a UK-registered SIPP with features tailored to expats, such as:
- Multi-currency options
- Remote access
- Flexible investment administration
Both an International SIPP and a QROPS are favourable choices for expats, as they allow the consolidation and management of pensions from abroad. However, these products operate under distinct rules and thus suit different circumstances.
A key distinction between the two structures is flexibility. International SIPPs are generally more flexible, as they allow for the management of transfers, withdrawals, and contributions with fewer restrictions.
By contrast, QROPS flexibility varies by jurisdiction. Benefit access, permitted investment structures, and retirement age rules are determined locally and may include constraints not present in a UK-regulated SIPP.
International SIPPs often have lower ongoing charges than many QROPS, although fees vary significantly between providers and jurisdictions. Many International SIPPs also provide access to a broader range of investment options than some overseas pension schemes. However, withdrawals may be subject to UK income tax, and the funds remain within the UK IHT framework, starting from April 2027.
Conversely, if you live in a jurisdiction with a favourable double taxation agreement and have no intention of returning to the UK, a QROPS could provide greater long-term tax efficiency.
Additionally, depending on the QROPS jurisdiction, local inheritance or estate tax rules may be more advantageous than the UK framework. This is particularly important given the April 2027 changes that bring most pension funds within the scope of UK estate for IHT purposes.
Frequently Asked Questions
HMRC updates the ROPS list twice per month, typically on the 1st and 15th. If your chosen scheme is delisted mid-transfer, what happens next depends on when the transfer was completed. Transfers completed before delisting are generally treated as authorised. On the other hand, transfers processed after delisting may be treated as unauthorised payments, and thus attract a 40% charge and a potential 15% surcharge.
The OTC applies at the point of transfer unless the QROPS is based in your country of tax residence. If you meet the residency condition at transfer and the OTC is waived, but you subsequently move to a different country within five full UK tax years, HMRC can retroactively apply the 25% charge to the original transfer value.
From 6 April 2027, the UK intends that most unused pension funds and death benefits, including those held in many QROPS, will be brought within the scope of UK inheritance tax for individuals who remain within the residence-based IHT regime. The exact position depends on the legislation in force at the date of death and the individual’s residence status. However, if you are no longer an LTR, i.e., you have not been UK tax-resident for at least 10 of the previous 20 tax years, you may fall outside the scope of UK IHT on non-UK assets, including any QROPS death benefits.
The unauthorised payment charge arises when a transfer is made to a scheme that does not qualify as ROPS, attracting a 40% charge on the member, with a 15% surcharge and a scheme sanction charge on the administrator. The OTC is a separate 25% charge that applies to transfers made to a qualifying ROPS where the residency condition is not met. Both charges can apply if a transfer fails on multiple grounds, though in practice, the OTC assumes a valid ROPS is in place, making the application of both penalties uncommon.
Yes, up to 25% of your fund can be taken as a tax-free lump sum, subject to the Lump Sum Allowance (LSA) of £268,275. Once the available Lump Sum Allowance has been used, the tax treatment of any further withdrawals depends on the UK tax rules, your country of residence and any applicable double taxation agreement. How the lump sum is treated in your country of residence depends on the local tax rules and whether a double taxation agreement with the UK applies.
Key Takeaway
Understanding the QROPS list is an important first step for UK expats considering the transfer of a UK pension overseas. Checking that a receiving scheme appears on HMRC’s published QROPS list helps support a compliant transfer, but it should always be considered alongside your tax residence, the applicable transfer rules and the scheme’s ongoing eligibility.
This guide has explained the purpose of the QROPS list, outlined the statutory requirements overseas pension schemes must meet, examined the risks of transferring to a scheme that does not satisfy those requirements, and highlighted the potential tax and estate-planning advantages that may be available in the right circumstances, together with recent legislative changes that could affect future planning.
At Titan Wealth International, our cross-border pension specialists can review your existing pension arrangements and explain the options available based on your circumstances. Where appropriate, we can help assess whether your current structure remains suitable, identify opportunities to improve efficiency, and ensure your retirement planning continues to reflect your residency status and long-term objectives.
The information provided in this article is not a substitute for personalised financial, tax or legal advice. You should obtain financial advice and tax advice tailored to your particular circumstances and in respect of any jurisdictions where you may have tax or other liabilities. Titan Wealth International accepts no liability for any direct or indirect loss arising from the use of, or reliance on, this information, nor for any errors or omissions in the content.
