If you’re planning to retire in France, it’s worth understanding how your UK pension will be taxed before considering a transfer. In many cases, UK private pensions paid to French tax residents are taxed under the UK-France Double Tax Convention, meaning a transfer isn’t necessarily required to achieve favourable tax treatment.
Whether transferring your pension is suitable depends on your circumstances, the pension scheme involved and the options available.
Depending on where the pension is held and your future plans, transferring overseas may reduce your exposure to certain UK pension rules. However, UK tax legislation can still affect overseas pension arrangements in some circumstances.
This article explains why there are currently no recognised QROPS in France, what alternatives are available for UK pension holders living in France, and the key tax and practical considerations before deciding whether an overseas pension transfer is right for you.
What You Will Learn
- Can you transfer your UK pension to a QROPS in France?
- Why are there currently no recognised QROPS in France?
- What alternatives are available if you want to transfer your UK pension while living in France?
- What are the tax implications of transferring a UK pension as a French resident?
Can You Transfer a UK Pension to a QROPS in France?
No. France currently has no pension schemes recognised by HMRC as Qualifying Recognised Overseas Pension Schemes (QROPS), so a direct transfer from a UK registered pension to a French QROPS isn’t possible.
French pension schemes previously appeared on HMRC’s QROPS list, but none are currently recognised. The earlier PERP (Plan d’Épargne Retraite Populaire) arrangements no longer satisfy the conditions required for QROPS status.
One of the key differences between the UK and French pension systems is when retirement savings can be accessed. UK registered pensions are generally available from the Normal Minimum Pension Age (currently 55, rising to 57 from 6 April 2028 unless a protected pension age applies). French retirement products operate under different access rules, and some allow withdrawals in circumstances that UK pension legislation would not normally permit.
For example, certain French retirement products may permit early access in limited circumstances, including:
- Serious illness
- The expiry of unemployment benefit entitlement
- Over-indebtedness in qualifying cases
- The death of a spouse or civil partner
Although both are designed for long-term retirement saving, a French Plan d’Épargne Retraite (PER) and a QROPS serve different legal and tax purposes. A PER is a domestic French retirement savings product, whereas a QROPS is a UK tax classification for certain overseas pension schemes recognised by HMRC.
How Can You Transfer a UK Pension to France?
Transferring a UK registered pension to an overseas scheme that is not recognised by HMRC as a Qualifying Recognised Overseas Pension Scheme (QROPS) is generally treated as an unauthorised payment for UK tax purposes.
This can result in an unauthorised payments tax charge of at least 40%, with additional tax charges possible in some circumstances. In practice, many UK pension providers will not facilitate these transfers.
Previously, some UK pension holders transferred their pensions to a QROPS in another European Economic Area (EEA) jurisdiction and then received their pension income in France. Under the rules that applied at the time, this could avoid both the unauthorised payments charge and, in certain circumstances, the 25% Overseas Transfer Charge (OTC).
However, the Autumn Budget 2024 removed the EEA and Gibraltar exemption with immediate effect. From 30 October 2024, the most relevant exemption from the 25% Overseas Transfer Charge is the jurisdiction-match rule. This requires the QROPS to be established in the same jurisdiction where the member is tax resident. Because there are currently no recognised QROPS in France, this exemption is generally unavailable to UK pension holders who are tax resident in France.
You may still qualify for an exemption from the Overseas Transfer Charge if the QROPS is one of the following:
- An occupational pension scheme
- An overseas public service pension scheme
- A pension scheme established by an international organisation
These exemptions apply only where the relevant conditions are met. For occupational, overseas public service and international organisation pension schemes, this generally includes being employed by a participating employer at the time of the transfer. From 6 April 2026, QROPS scheme managers must also satisfy HMRC’s UK residency requirements.
Because overseas pension transfers involve complex UK and local tax rules, professional advice is usually recommended before making a decision.
Titan Wealth International can assess your circumstances and advise whether an overseas transfer, or leaving your pension in the UK, is likely to be the more suitable option.
Exploring Your Pension Options While Living in France?
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.
International SIPPs: An Alternative for UK Expats in France
If a QROPS isn’t available or appropriate, an international Self-Invested Personal Pension (SIPP) may be an alternative worth considering. An international SIPP is a UK-registered personal pension that can accept transfers from many UK pension schemes while remaining subject to UK pension legislation and regulation.
Some of the main differences between an international SIPP and a QROPS include:
| International SIPP | QROPS |
|---|---|
| Typically based in the UK but available to UK nationals living overseas | Established outside the UK in a jurisdiction recognised by HMRC |
| Subject to UK pension and tax rules | Tax treatment depends on your country of residence, the QROPS jurisdiction and local tax law |
| Often provides access to a broad range of investments, including shares, bonds and funds | Investment options vary depending on the provider and jurisdiction |
| Regulated by the Financial Conduct Authority (FCA) and UK pension legislation | Regulated by the financial regulator in the jurisdiction where the QROPS is established |
| Charges vary between providers and should be reviewed before transferring | Charges vary between providers and jurisdictions and should be reviewed carefully before transferring |
What Are the Benefits of Moving a UK Pension to an International SIPP?
Transferring your UK pension to an international SIPP may offer several advantages, depending on your circumstances:
| Benefit | Details |
|---|---|
| Withdrawal Flexibility | International SIPPs allow you to manage your pension while living overseas, with benefits generally available from the Normal Minimum Pension Age under UK rules (currently 55, rising to 57 from 6 April 2028 unless a protected pension age applies). You can usually take up to 25% of your pension as a tax-free lump sum under UK rules, with the remainder left invested or drawn as income. However, this lump sum may still be taxable if you are resident in France. |
| Tax Efficiency | The UK-France Double Tax Convention helps determine which country has the primary right to tax pension income and is designed to prevent the same income from being taxed twice. Your overall tax position will depend on your residency and individual circumstances. |
| Currency Management | Many international SIPPs offer multi-currency facilities, allowing you to hold investments or cash in major currencies, including euros. This may help reduce exposure to exchange rate fluctuations if you expect to spend your retirement in France. |
| Estate Planning | Personal pensions have historically fallen outside a member’s estate for UK inheritance tax (IHT) purposes. However, from 6 April 2027, unused pension funds and death benefits may be included in a member’s estate for IHT purposes under new UK legislation. As the final rules continue to develop, anyone with cross-border estate planning considerations should review their arrangements regularly. |
Before transferring a pension, obtain regulated financial advice to ensure the arrangement is suitable for your circumstances.
Key Inheritance Tax Considerations of Transferring a UK Pension to an International SIPP
Historically, unused SIPPs and other personal pensions were generally outside a deceased member’s estate for UK inheritance tax (IHT) purposes. Where a member died before age 75, beneficiaries could also receive the pension free of UK income tax, provided the benefits were designated within the required timescales.
From 6 April 2027, unused pension funds and pension death benefits are expected to form part of a member’s estate for UK inheritance tax purposes. Inheritance tax is generally charged at 40% on the value of an estate above the available thresholds and reliefs. Responsibility for reporting and paying any IHT due will also move from pension scheme administrators to the deceased’s personal representatives.
The planned changes do not apply to:
- Death-in-service benefits paid from registered pension schemes
- Existing exemptions for transfers to a surviving spouse or civil partner
- Transfers to registered charities
Where a member dies on or after age 75, pension benefits paid to beneficiaries may also be subject to income tax at the recipient’s marginal rate, in addition to any inheritance tax that may apply.
Living in France does not necessarily remove exposure to UK inheritance tax. Since 6 April 2025, the UK has operated a residence-based inheritance tax regime, replacing the previous domicile-based system.
Individuals who qualify as UK long-term residents (LTRs) may remain within the scope of UK inheritance tax on their worldwide assets for a period after leaving the UK, depending on how long they were a UK tax resident.
For UK nationals living in France, both UK and French inheritance tax rules may need to be considered when planning how pension benefits will pass to future generations.
Guide
Retirement Planning And Pension Advice For British Expats In France
Retirement planning for British expats in France is rarely about a single pension or investment decision. This guide explains how retirement planning actually works in practice — from structuring and consolidation to drawdown and tax-efficient income.
French Succession Tax on UK Pensions: The Inheritance Trap for HNW Heirs
If you are a UK national who is tax resident in France, your estate may be subject to French succession tax on worldwide assets, depending on your circumstances and the applicable succession tax rules. The rates and allowances depend on the value of the inheritance and your relationship with the beneficiary.
| Relationship With the Heir | Tax-Free Allowance | Tax Rate |
|---|---|---|
| Spouse or civil partner | N/A | 0% |
| Child | €100,000 | 5%–45% |
| Sibling | €15,932 | 35%–45% |
| Nephew or niece | €7,967 | 55% |
| Other (including unmarried partners and stepchildren) | €1,594 | 60% |
From 6 April 2027, French residents who remain within the scope of UK inheritance tax as long-term UK residents could, depending on their circumstances, face both UK inheritance tax and French succession tax on the same assets. In some cases, pension benefits may also be subject to French income tax when beneficiaries withdraw them.
The UK-France Double Tax Treaty helps prevent the same pension income from being taxed twice by allocating taxing rights between the two countries. However, it does not currently provide comprehensive relief where both UK inheritance tax and French succession tax apply to the same assets.
Because cross-border estate planning involves both UK and French tax rules, professional advice is strongly recommended before making pension or succession planning decisions. An adviser can assess your exposure to UK inheritance tax, French succession tax and any available reliefs based on your individual circumstances.
Alternative Options for Transferring a UK Pension to France
If a QROPS isn’t available or you decide not to keep your pension in the UK, you may wish to consider one of the following options:
- Taking your UK pension as a lump sum
- Investing through an Assurance-Vie
Taking Your UK Pension as a Lump Sum
One option is to withdraw your pension as an Uncrystallised Funds Pension Lump Sum (UFPLS). If you’re eligible to access your pension, a UFPLS allows you to take benefits directly from your pension without first moving into drawdown.
Where the withdrawal qualifies under Article 163 bis II of the French Code Général des Impôts, the lump sum may be taxed at a fixed rate of 7.5%, after applying the available 10% deduction, resulting in an effective income tax rate of 6.75%.
To qualify, the payment must generally be made as a single lump sum representing the complete liquidation of your rights under that pension scheme. Taking earlier partial withdrawals, including a UK Pension Commencement Lump Sum (PCLS), will usually prevent the preferential tax treatment from applying.
French social charges of up to 9.1% may also apply, depending on your circumstances, although exemptions are available in some cases, including for individuals who hold a valid Form S1 or are not affiliated with the French healthcare system. Depending on your circumstances, this approach may be more tax-efficient than attempting to transfer a UK pension to a pension scheme that is not recognised by HMRC.
Consider the Assurance-Vie Option
For UK nationals living in France, an Assurance-Vie is a widely used long-term investment and estate planning product. Depending on your circumstances, it can offer tax advantages, succession planning benefits and investment flexibility under French law.
Funds held within an Assurance-Vie benefit from tax deferral, meaning investment gains are generally not subject to French income tax while they remain within the policy. There is no statutory limit on contributions, making it a flexible long-term investment vehicle. Once a policy has been held for more than eight years, qualifying withdrawals may benefit from more favourable tax treatment and an annual tax allowance.
Taxation of Withdrawals
Withdrawals Before Eight Years
Gains realised on withdrawals made within the first eight years are generally subject to the Prélèvement Forfaitaire Unique (PFU), currently 30%, comprising 12.8% income tax and 17.2% social charges.
Withdrawals After Eight Years
Where qualifying conditions are met, gains relating to premiums within the €150,000 threshold are generally taxed at 7.5% income tax plus 17.2% social charges, giving a combined rate of 24.7%.
Where total qualifying premiums exceed €150,000, the taxation becomes more complex. The 7.5% income tax rate continues to apply to the qualifying portion of gains relating to premiums within the €150,000 threshold, while gains attributable to qualifying premiums above that threshold are generally taxed at 12.8% income tax plus 17.2% social charges.
Qualifying gains may also benefit from an annual tax allowance of:
- €4,600 for an individual
- €9,200 for a married couple or PACS partners filing jointly.
Frequently Asked Questions
French social charges may still apply, depending on your circumstances. Individuals who are affiliated with the French healthcare system are generally liable to social charges of up to 9.1%. Exemptions may apply, including where you hold a valid Form S1 or are not affiliated with the French healthcare system.
In most cases, transfers to a surviving spouse or civil partner benefit from spouse exemptions under both UK inheritance tax and French succession tax rules. However, the precise tax treatment will depend on the type of pension, the applicable legislation at the time of death and your personal circumstances.
Whether an Assurance-Vie offers better long-term tax efficiency than a UK SIPP depends on how and when you plan to access your retirement income.
Taking your entire UK SIPP as an Uncrystallised Funds Pension Lump Sum (UFPLS) may qualify for the preferential tax treatment available under Article 163 bis II of the French Code Général des Impôts, resulting in an effective French income tax rate of 6.75% (7.5% after the available 10% deduction), or 15.85% where French social charges of 9.1% also apply.
By comparison, qualifying gains withdrawn from an Assurance-Vie held for more than eight years are generally taxed at a combined rate of 24.7% (7.5% income tax plus 17.2% social charges) on gains relating to qualifying premiums within the €150,000 threshold.
However, if you do not qualify for the preferential lump-sum treatment under Article 163 bis II and instead take pension income through drawdown, your UK pension is generally taxed in France at your applicable marginal income tax rate. In those circumstances, an Assurance-Vie may provide a more favourable long-term tax outcome for some individuals, particularly where funds are intended to remain invested over many years.
The French 10% pension allowance of up to €4,123 per couple applies to income from all your UK pensions, except for UK government service pensions, which remain taxable in the UK. That means that both your UK State Pension and private pension benefits, such as payments from a SIPP, are taxable in France at your marginal income tax rate of up to 45% after the 10% deduction.
If you intend to take your 25% pension commencement lump sum (PCLS), doing so before becoming a French tax resident may preserve its UK tax-free treatment. Once you become a French tax resident, the French tax treatment can differ and the lump sum may be taxable. Whether this approach is appropriate depends on your wider tax position and retirement plans.
Some individuals instead consider taking benefits as a UFPLS, which may qualify for the preferential taxation available under Article 163 bis II of the French Code Général des Impôts where all qualifying conditions are met.
Your Complimentary QROPS Review
If you live in France and hold a QROPS, or you’re planning to move there, our cross-border pension specialists can review your existing arrangements and explain the options available to you.
- Review your existing QROPS and pension arrangements
- Understand the UK and French tax implications
- Explore alternative pension options where appropriate
Key Takeaway
While it is not possible to transfer a UK pension directly to a QROPS in France, UK expats living in France still have several options for managing their pension arrangements. The most appropriate approach will depend on their residency, tax position and retirement objectives.
Recent changes to UK pension and inheritance tax rules have altered the considerations for many UK nationals living in France, and further legislative changes may continue to affect cross-border pension planning.
Cross-border pension planning involves UK and French tax rules, pension legislation and, in some cases, the UK–France Double Taxation Convention. Because the most appropriate approach depends on your personal circumstances, obtaining regulated cross-border financial advice before transferring or accessing your pension can help you understand the options available and their tax implications.
Titan Wealth International advises UK nationals living overseas on cross-border pension planning, helping clients assess their existing pension arrangements and understand the available options in light of their residency, tax position and retirement 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.
