Where is Your Client Resident?

Technical disclaimer – This section of the website is only directed at financial advisers, professional, institutional or qualified investors and is not suitable for retail investors. If you remain on this page, you understand and declare that you qualify as one of the above and that you are not a retail investor as defined in the relevant jurisdiction legislation.

General Rule of Thumb


Before taking benefits

A client should consider the option of transferring their pension to a QROPS if:

  • they are resident in a jurisdiction that has a local retail QROPS available; and
  • they intend to remain in that jurisdiction for the next five full tax years

If the client is not intending to maintain their current residency for the next 5 full UK tax years, they will need to consider if the jurisdiction they are moving to also has a retail QROPS available.

If none of the above applies, then the client needs to consider leaving their pension in the UK, in a product such as a SIPP, otherwise a transfer may be subject to a 25% tax charge. This may be in the clients best interest if:

  • they are concerned that further detrimental changes may occur to the QROPS legislation; or
  • if they know the 25% transfer tax charge will be a better option for them

On taking benefits

At the point of taking benefits and the client is resident in a jurisdiction that has a local retail QROPS available (not subject to the 25% tax charge), it may be in the client’s best interest to consider a transfer to that QROPS.

If at the point of taking benefits the client is resident in a jurisdiction that does not have a local retail QROPS available to them then the client would need to consider:

  • taking benefits from a UK SIPP with tax under UK PAYE (up to 45%); or
  • if there is any effective DTA in place compared to taking a transfer to a New Zealand QROPS (with a flat 25% tax charge), taking the benefits from there at 0% New Zealand tax.

** Only available from the age of 55 **

Any UK taxable withdrawal over £60,000 could generate a higher effective tax charge than the 25% transfer tax

Where is Your Client Resident?


Here you will find guides to suggested products and benefits that apply to residents in the jurisdictions which are popular for many expats to retire to.

The EEA is comprised of the European Union (EU) as well as Liechtenstein, Iceland and Norway so has multiple retirement destinations for UK expats. Once resident in the EEA and have completed the transfer of UK Pension money, you can freely move about the EEA without incurring any tax charges.

As Gibraltar is classed as an EEA territory, you would be able to transfer your UK pension to the IVCM Gibraltar QROPS without the Overseas Transfer Charge applying.

Most EEA countries will have a Double Tax Treaty in force with the UK and therefore the SIPP is an option for those who wish to keep their pension fund in the UK.

If you transfer from a UK Pension to a New Zealand QROPS, fund growth and benefits payable will be free of tax. The transfer will however be subject to the Overseas Transfer Charge. This may be more tax beneficial so would be something to consider when cashing out large lump sums.

Key Considerations

  • Tax on income withdrawals
  • Double taxation agreements (DTA)
  • Overseas transfer charge (OTC)

Available IVCM Products

  • Gibraltar Expat Retirement Annuity
    -No OTC and low tax at source (2.5%)
  • IVCM (NZ) PIE Superannuation Fund
    -0% Tax on income withdrawals but OTC may apply on transfer

Australia is the most popular destination for British expats. Residents of Australia can transfer their UK pension to an Australian QROPS which would not be subject to the Overseas Transfer Charge. The Australian Expatriate Superannuation Fund is an ideal savings vehicle for a resident of Australia as once members reach age 60, all benefits paid from the Superannuation are tax free and there is no tax on the growth of the fund.

Alternatively, if a transfer to an Australian QROPS is not suitable, a transfer from a UK pension fund to a New Zealand QROPS may as the benefits payable and fund growth are both tax free. This would however attract the Overseas Transfer Charge. A transfer to a New Zealand QROPS may be more tax beneficial even if the transfer is subject to the Overseas Transfer Charge. New Zealand and Australia have a favourable DTA regarding withdrawals from a New Zealand Superannuation Fund.

Key Considerations

  • Tax on income withdrawals
  • Double taxation agreements (DTA)
  • Overseas transfer charge (OTC)
  • Holding vehicle prior to age 55

Available IVCM Products

  • Australian Expat Superannuation Fund
    – 0% Tax on income withdrawals over age 60
  • IVCM (NZ) PIE Superannuation Fund
    – Australia & NZ have a favourable DTA regarding withdrawals from a New Zealand Superannuation Fund.
    – 0% Tax on income withdrawals but OTC may apply

New Zealand is an extremely popular retirement destination for British Expatriates. It hosts one of the most favourable tax regimes as payments from NZ Superannuation funds are paid free of tax and if you decide to move elsewhere in the world, you may be able to utilise one of New Zealand’s many Double Taxation Agreements.

The UK has a Double Taxation Agreement (DTA) in place with New Zealand which grants the taxing rights for the income to the country of residence and therefore a SIPP may be the most suitable scheme if you do not want to transfer your pension to New Zealand.

Key Considerations

  • Tax on income withdrawals
  • Double taxation agreements (DTA)

Available IVCM Products

  • IVCM (NZ) PIE Superannuation Fund
    – 0% Tax at source on income withdrawals (PIR=0%)

The Middle East has a large population of British Expats however there are very little retirees due to visa restrictions. Many British expats seek employment in the middle east due to the high earning potential and low tax regime.

As the Middle East has no QROPS schemes, to avoid the Overseas Transfer Charge the fund must remain in the UK and therefore a SIPP would be the best option. The UK has a DTA in force with most of the countries in the Middle East which grants the taxing rights for the income to the country of residence.

If the member is unable to claim the Double Tax Treaty, a transfer to a New Zealand QROPS may be more beneficial as there will be no tax at source on income withdrawals and it would not be payable in the country of residence. The transfer would however be subject to the Overseas Transfer Charge.

Key Considerations

  • Double taxation agreements (DTA)
  • Overseas transfer charge (OTC)
  • Tax on income withdrawals
  • No QROPS in Middle East

Available IVCM Products

  • IVCM (NZ) PIE Superannuation Fund
    – 0% Tax at source on income withdrawals using a UK DTA
    – 0% Tax at source on income withdrawals (PIR=0%) but OTC may apply
  • Gibraltar Retirement Annuity Trust QROPS
    – 25% OTC may apply

Hong Kong is one of the most significant financial centres in the world so is a popular place for many expats.
Hong Kong has several QROPS schemes however you should consult a local adviser on the suitability of these.

A SIPP may be the most suitable option as the UK has a DTA with Hong Kong although the DTA states that the income from a UK pension would be taxable in the UK. A transfer to a New Zealand QROPS may be a more beneficial option as there will be no tax at source on income and won’t be payable in the country of residence. This should be considered when making large income withdrawals. The transfer would however be subject to the Overseas Transfer Charge.

Key Considerations

  • Double taxation agreements (DTA)
  • Overseas transfer charge (OTC)
  • Tax on income withdrawals
  • No retail Hong Kong QROPS

Available IVCM Products

  • IVCM (NZ) PIE Superannuation Fund
    – 0% Tax at source on income withdrawals (PIR=0%)
  • Gibraltar Retirement Annuity Trust QROPS
    – 25% OTC may apply

The Far East has many destinations that are popular for expats due to the cheap cost of living.

As the Far East has no retail QROPS schemes, to avoid the Overseas Transfer Charge the fund must remain in the UK and therefore a SIPP would be the best option. The UK has a DTA in force with most of the countries in the Far East which grants the taxing rights for the income to the country of residence.

A New Zealand QROPS may be more beneficial as there will be no tax at source on the income and won’t be payable in the country of residence. This would however be subject to the Overseas Transfer Charge.

Key Considerations

  • Double taxation agreements (DTA)
  • Overseas transfer charge (OTC)
  • Tax on income withdrawals
  • No retail Hong Kong QROPS

Available IVCM Products

  • IVCM (NZ) PIE Superannuation Fund
    – 0% Tax at source on income withdrawals using a UK DTA
    – 0% Tax at source on income withdrawals (PIR=0%) but OTC may apply
  • Gibraltar Retirement Annuity Trust QROPS
    – 25% OTC may apply

Switzerland attracts many expats with job opportunities, high salaries and a great standard of living.
Switzerland does have a local QROPS however you should consult a local adviser on the suitability of this scheme. It should also be noted that Switzerland is NOT an EEA country.

The UK has a DTA in force with Switzerland which grants the taxing rights for the income to the country of residence, and therefore a SIPP may be the most suitable option.

If the member is unable to claim the Double Tax Treaty or the local tax rate is high, a transfer to a Gibraltar QROPS may be beneficial as there will be only 2.5% tax at source on the income and Gibraltar has no Double Tax treaties in place. This would however be subject to the Overseas Transfer Charge.

Key Considerations

  • Double taxation agreements (DTA)
  • Overseas transfer charge (OTC)
  • Tax on income withdrawals

Available IVCM Products

  • IVCM (NZ) PIE Superannuation Fund
    – 0% Tax at source on income withdrawals (PIR=0%) but OTC may apply
  • Gibraltar Retirement Annuity Trust QROPS
    – 25% OTC may apply

South Africa may be a popular retirement destination for expats due to the cheap cost of living.

South Africa does have a local QROPS however you should consult a local adviser on the suitability of this scheme.

The UK has a DTA in force with South Africa which grants the taxing rights for the income to the country of residence, and therefore a SIPP may be the most suitable option.

If the member is unable to claim the Double Tax treaty relief or the local tax is high, a transfer to a New Zealand QROPS may be beneficial as there will be no tax at source on the income and won’t be payable in the country of residence. This would however be subject to the Overseas Transfer Charge.

Key Considerations

  • Double taxation agreements (DTA)
  • Overseas transfer charge (OTC)
  • Tax on income withdrawals

Available IVCM Products

  • IVCM (NZ) PIE Superannuation Fund
    – 0% Tax at source on income withdrawals (PIR=0%) but OTC may apply
  • Gibraltar Retirement Annuity Trust QROPS
    – 25% OTC may apply

The United States is popular with British expats as it is home to many of the world’s global companies.

The USA does have a local QROPS however you should consult a local adviser on the suitability of this scheme.

The UK has a DTA in force with the USA which grants the taxing rights for the income to the country of residence, and therefore a SIPP may be the most suitable option.

If the member is unable to claim the Double Tax Treaty or the local tax rate is high, a transfer to a Gibraltar QROPS may be beneficial as there will be only 2.5% tax at source on the income and Gibraltar has no Double Tax treaties in place. This would however be subject to the Overseas Transfer Charge.

Key Considerations

  • Double taxation agreements (DTA)
  • Overseas transfer charge (OTC)
  • Tax on income withdrawals

Available IVCM Products

  • IVCM (NZ) PIE Superannuation Fund
    – 0% Tax at source on income withdrawals (PIR=0%) but OTC may apply
  • Gibraltar Retirement Annuity Trust QROPS
    – 25% OTC may apply

Canada does have a local QROPS however you should consult a local adviser on the suitability of this scheme.

The UK has a DTA in force with Canada which grants the taxing rights for the income to the country of residence, and therefore a SIPP may be the most suitable option.

You could transfer to a QROPS and this would be subject to the Overseas Transfer Charge. However, this could be an option where the member is unable to claim the Double Tax treaty relief or the local tax rate is high, a Gibraltar QROPS may be more beneficial as there will be only 2.5% tax at source on the income and Gibraltar has no Double Tax treaties in place.

Key Considerations

  • Double taxation agreements (DTA)
  • Overseas transfer charge (OTC)
  • Tax on income withdrawals

Available IVCM Products

  • IVCM (NZ) PIE Superannuation Fund
    – 0% Tax at source on income withdrawals (PIR=0%) but OTC may apply
  • Gibraltar Retirement Annuity Trust QROPS
    – 25% OTC may apply

A SIPP would be the most suitable scheme for those residents in the UK. Although a transfer to a QROPS in the EEA would not be subject to the Overseas Transfer Charge, the benefits of a QROPS for a resident of the UK remain very limited.

Key Considerations

  • Overseas transfer charge (OTC)

Available IVCM Products

  • IVCM (NZ) PIE Superannuation Fund
    – 0% Tax at source on income withdrawals (PIR=0%) but OTC may apply
  • Gibraltar Retirement Annuity Trust QROPS
    – QROPS benefits to a UK resident are limited
    – 25% OTC may apply for transfers to QROPS outside of the EEA

Unless a local QROPS is available, you should check whether the country of residence has a DTA in force with the UK and the subsequent tax rates. A transfer to a QROPS in New Zealand or Gibraltar may be more tax beneficial even if the transfer is subject to the Overseas Transfer Charge.

Key Considerations

  • Double taxation agreements (DTA)
  • Overseas transfer charge (OTC)

Available IVCM Products

  • IVCM (NZ) PIE Superannuation Fund
    – 0% Tax at source on income withdrawals (PIR=0%)
  • Gibraltar Retirement Annuity Trust QROPS
    – 25% OTC may apply

Any Questions?


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