Is It Possible To Transfer a UK Pension to France? Answered

As of September 2025, there are no French pension schemes recognised by HM Revenue & Customs (HMRC) as qualifying recognised overseas pension schemes (QROPS). This means that a direct transfer from a UK pension into a local French scheme is generally not possible without incurring UK tax charges.

Instead, British expats living in France usually explore alternatives such as retaining their UK pension, moving funds to a UK-based self-invested personal pension (SIPP), or considering a QROPS in another jurisdiction where conditions are met.

Choosing the right approach depends on your individual pension type, your French residency status, and the tax rules in both countries. Because this is a complex cross-border area, professional advice is essential before making any decision.

Can You Transfer a UK Pension to a French Scheme?

His Majesty’s Revenue and Customs (HMRC) permits overseas pension transfers only under specific conditions designed to protect you against abuse and unregulated pension arrangements.

These conditions relate to the characteristics of the receiving scheme. For instance, to receive a UK pension transfer, the overseas scheme must meet HMRC’s conditions to be recognised as a qualifying recognised overseas pension scheme (QROPS). To qualify, the scheme must generally:

• Be regulated or authorised under the pension or financial services law of its jurisdiction (if applicable).
• Be correctly registered with its local tax authority.
• Provide ongoing reporting to HMRC where required.
• Be established in a jurisdiction that has appropriate information exchange or treaty arrangements with the UK (unless an exemption applies).

At the time of writing, no French pension schemes are listed as QROPS on HMRC’s list. Transfers to local French schemes would therefore be treated as unauthorised payments under UK law, normally incurring UK tax charges such as the Overseas Transfer Charge (OTC) or unauthorised payment charges.

Can You Transfer Your Pension to a QROPS Outside of France?

Prior to the 2024 revision of QROPS rules, individuals residing in the UK, a European Economic Area (EEA) member state, or Gibraltar were generally permitted to transfer their UK pension to a QROPS in those jurisdictions without incurring the 25% overseas transfer charge (OTC).

For instance, this exemption allowed UK expats residing in France to transfer the full amount of their UK pension to a QROPS in Malta, Germany, or any other qualifying jurisdiction.

However, under the updated QROPS rules, transfers made to a QROPS outside an individual’s country of residence will normally be liable for the 25% OTC, unless a specific exemption applies (for example, certain occupational or public service schemes).

Transfers are also subject to the new Overseas Transfer Allowance (OTA), currently set at £1,073,100 (unless higher protections apply). The OTA is a lifetime allowance, and any previous benefit crystallisations or transfers may reduce the available amount. Amounts transferred above the OTA may trigger additional UK tax charges.

You may claim an OTC refund if, within five full UK tax years after the transfer, your circumstances change so that you meet an exemption (for example, by becoming resident in the country where the QROPS is based), and provided HMRC reporting requirements are met.

Can You Transfer a UK Pension to a Non-QROPS in France?

Under current UK regulations, transferring a UK pension to a non-QROPS in France would normally be treated as an unauthorised payment by HMRC.

This can attract significant UK tax charges, which in some cases may total up to 55% of the amount transferred. However, the exact liability depends on the scheme, the amount involved, and HMRC’s assessment of the transfer.

Can You Transfer a UK State Pension to France?

You cannot transfer your UK State Pension into a French scheme. However, you can claim it abroad and have it paid into a French or international bank account. To do so, you should take one of the following approaches:

1. Contact the International Pension Centre
2. Submit the international claim form to the International Pension Centre

Receiving your UK State Pension as a French resident does not affect your eligibility for annual pension increases. Pensioners in France continue to receive annual uprating because the UK has an agreement with France that preserves increases.

What Is the Alternative to Transferring Your UK Pension to France?

While you cannot transfer your UK pension directly into a French scheme, you may move it to an international self-invested pension plan (SIPP). This pension vehicle allows UK expats to consolidate their pension into one pot and continue contributing to it from abroad while enjoying expat-specific benefits, such as streamlined currency management and flexible pension access.

International SIPPs are UK-based pension arrangements and, as such, are subject to UK regulation. This includes oversight by the UK’s Financial Conduct Authority (FCA), which upholds high standards of consumer protection and governance.

Which UK Pensions Can Be Moved to an International SIPP?

Most UK expats can transfer their UK pension to an international SIPP, but eligibility depends on the type of pension they hold. The two most common types of private pensions in the UK—defined benefit (DB) and defined contribution (DC) pensions—are generally eligible for transfer to an international SIPP.

If you wish to transfer a defined benefit, also referred to as a final salary pension, consider the following:

• “Unfunded” public sector defined benefit schemes (such as those for teachers or NHS workers) aren’t eligible for the transfer.
• Obtaining defined benefit pension transfer advice is mandatory if your pension’s cash equivalent transfer value (CETV) exceeds £30,000. This requirement ensures that you fully understand the potential advantages and risks of the transfer and are well-equipped to make an informed decision.
• Defined benefit pensions provide a guaranteed income in retirement. Transferring them to an international SIPP will result in losing this guarantee, which may pose a significant financial risk.

Expats with a defined contribution pension should consider the following factors before initiating a transfer to an international SIPP:

• Engaging with a regulated defined contribution pension transfer adviser is mandatory if your DC pension includes special guarantees, such as a guaranteed annuity rate (GAR), whose value exceeds £30,000.
• There are two primary methods for transferring a DC pension to an international SIPP:
  • Cash transfer involves liquidating the existing investments within the DC pension and transferring the proceeds into an international SIPP.
  • In-specie transfer entails transferring the existing investments directly into an international SIPP without selling them. This approach is only feasible if the receiving SIPP provider supports the same types of investments as the original DC scheme.

Why Is Transferring to an International SIPP a Good Option for UK Expats?

International SIPPs offer a range of advantages specifically designed to meet the needs of UK expats, as outlined in the table below:

What Drawbacks Should You Consider Before Transferring to an International SIPP?

To determine whether international SIPPs align with your financial goals and long-term retirement plans, it is essential to consider their potential drawbacks:

• Limited tax relief eligibility: The UK government offers tax relief on private pension contributions worth up to 100% of your relevant UK earnings (subject to the annual allowance). This also applies to contributions made to SIPPs that accept non-UK residents. However, if you do not have relevant UK earnings, you can normally contribute up to £3,600 gross per year and still receive basic-rate tax relief. This allowance applies regardless of residence status, but may be restricted by the rules of individual schemes.
• Regulatory complexity: Transferring to an international SIPP and maximising its benefits requires a thorough understanding of both the UK and French pension and tax regulations. Compliance with cross-border rules is essential for avoiding unnecessary tax liabilities or administrative issues.

To fully understand the potential impact of these drawbacks on your pension and develop a strategy that maximises the benefits of international SIPPs while minimising risks, such as non-compliance with cross-border regulations, it’s highly recommended to consult with qualified pension transfer specialists.

At Titan Wealth International, our experienced expat advisers can evaluate your unique circumstances and offer comprehensive pension transfer advice that takes into account relevant regulations, your residency status, and your long-term financial and retirement objectives.

How Are UK Pensions Taxed in France?

Upon relocating to France and establishing French tax residence, you will generally be liable for French tax on your worldwide income, which includes both foreign and domestic pension entitlements.

French income tax rates are applied progressively based on net taxable income per household (number of “parts fiscales”) as follows:

You are also eligible for a 10% abatement (deduction) on pension income, with a minimum deduction of approximately €450 and a cap of about €4,399 per household. This reduces the amount of pension income subject to tax.

How Does the UK-France Double Taxation Treaty Work?

As a French tax resident receiving benefits from a UK-based pension scheme, such as an international SIPP, you may be liable for tax on the same income in both jurisdictions. To protect their tax residents from double taxation and ensure a fair allocation of taxing rights, France and the UK have entered into a double taxation treaty.

Under the treaty, the primary taxing rights on your pension income are allocated based on the type of your pension:

1. Private UK pensions, including SIPPs and the UK State Pension, are generally taxable in France if you are a French resident. However, French social charges may also apply unless you hold an exemption.
2. UK government pensions (for example, those paid to civil servants, teachers, armed forces, or local government employees) are normally taxable only in the UK under Article 19 of the treaty. These pensions must still be declared in France, where they are usually exempt from French income tax but may be taken into account in calculating your overall effective tax rate.